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CASES

Each week we report the tax cases that matter. Tax Journal subscribers have unrestricted access to the full archive, covering hundreds of cases.

Notice of tax claim under tax covenant was invalidIn Dodika v United Luck Group Holdings Ltd [2020] EWHC 2101 (Comm) (31 July 2020), the High Court held that written notice of a tax claim under a tax covenant was invalid because it did not comply...

Meaning of voting rights for entrepreneurs’ relief.

Inheritance tax consequences of pension transfer.

PAYE disputePAYE operates very effectively most of the time but when things go wrong sorting them out can be surprisingly complex. In Sci-Temps Ltd v HMRC [2020] UK FTT 314 (TC), insufficient tax was deducted from an employees pay and HMRC...

High Court decides ‘subject to tax’ in SPA gross-up clause means actual tax due.

Taxpayer refused judicial review of HMRC’s voiding of statutory clearance given on company share buyback.

Allegations of deliberate misrepresentationsHMRC v IGE Investments Ltd and others [2020] EWHC 2121 (Ch) (31 July 2020) is an immensely complex procedural decision about the way in which HMRCS case against a large international group should be...

Goodwill following transfer of practices to company.

Essay writing company was acting as principal for VAT.

Mutuality of obligation crucial in UT’s reversal of FTT’s IR35 decision.
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