CASES

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

SDLT appeal against closure notice:A Sajedi and others v HMRC [2026] UKUT 101 (TCC) (24 September 2025) concerned an arrangement which was designed to obtain the relief from higher rates of SDLT available where a person replaces his or her main...

Scope and operation of the ‘imported loss’ restriction in CTA 2009 s 327 for loan relationships

Pre-registration input tax

Discovery assessments out of time

Transactions in securities regime: I Oscroft and others v HMRC [2026] UKFTT 251 (TC) (12 February) confirms HMRC’s long-standing view (put beyond doubt by a subsequent amendment to the legislation) that profits available for distribution include...

Timing of VAT on mobile phone plan bundles

Paddock was part of grounds for SDLT purposes

VAT and services received from abroad

Discovery assessment in respect of travelling expenses: In F Uzoh v HMRC [2026] UKFTT 231 (TC) (5 February), an employee, who had not been within self-assessment, signed up with a repayment agent ‘Tommy’s Tax’, which then filed tax returns on his...

Class 1A NICs on ‘pooled’ cars: 1993 agreement gives no estoppel or legitimate expectation

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