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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.
P Malde v HMRC
VAT on legal fees not input tax for sole proprietorship
Blackrock Investment Management (UK) Ltd
Apportionment of consideration for a single supply
A Davies v HMRC
UT decides taxpayers did not benefit from motive exemption or qualify for treaty relief
P Higgs and Others v HMRC
Jurisdiction of the tribunal over PAYE regulations
D Moulsdale t/a Moulsdale Properties v HMRC
Disapplication of the option to tax
San Domenico Vetraria SpA v Agenzia delle Entrate, Ministero dell’Economia e delle Finanze
Secondment of staff to subsidiary
Pensfold v HMRC
SDLT 15% rate
Other cases that caught our eye: 18 March 2020
IR35An amended version of the decision in RALC Consulting Ltd v HMRC [2019] UKFTT 703 (TC) has been published. The FTTs decision (that the arrangements were outside IR35) remains the same but extra detail is given, primarily in respect of the...
R (oao Reid and Emblin) v HMRC; Reid and Emblin v HMRC
UT clarifies scope of certain APN conditions
Smith & Nephew Overseas Ltd v HMRC
Exchange losses on a change in functional currency and the ‘fairly represent’ requirement
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407
EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
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CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
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Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
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Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
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The new Securities Transfer Tax: business as usual?
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