CASES

HMRC’s powers: Soft Drinks Levy

SEISS (and AI): In HMRC v M Gunnarsson [2025] UKUT 247 (TCC) (23 July), the taxpayer operated through a personal service company and was therefore ineligible for Coronavirus Self-Employment Income Support Scheme (SEISS). He nonetheless applied for...

FTT dismisses taxpayer’s appeal against chargeable gains degrouping charge

No right of appeal against consequential amendments to partners’ returns

LBTT transition from SDLT: In Archer UK Ltd v Revenue Scotland [2025] FTSTC 10 (10 July), the Scottish FTT upheld the taxpayers appeal that the variation and extension of a lease did not constitute a land transaction as the grant of a...

Scottish FTT upholds Revenue Scotland’s assessments relating to incorrectly claimed LBTT group relief

How do random number generators work?

Partial wins for taxpayers in late appeal cases

JR challenge to APNs refused: In R(oao Adviser Business Solutions Ltd and others) v HMRC [2025] EWHC 1641 (Admin) (30 June), the HC refused permission to challenge Accelerated Payment Notices (APNs), holding that where HMRC have already formed...

Taxpayer breached the extraction of value rule for business investment relief purposes