CASES

In J Dickinson and others v HMRC [2018] EWCA Civ 2798 (18 December 2018), the Court of Appeal upheld the High Court’s decision not to grant judicial review of APNs (FA 2014 s 219) issued by HMRC, despite an earlier promise not to enforce payment...

In K Tutty v HMRC [2019] UKFTT 3 (31 December 2018), the FTT found that a discovery made following the use of an electronic standard information package (‘E-SIP’) was not stale. Ms Tutty had implemented arrangements to avoid SDLT and HMRC had issued...

Our pick of this week's cases   In R Dennis v HMRC [2018] UKFTT 735 (14 December 2018), the FTT found that a rebalancing payment made pursuant to a shareholders’ agreement was not made under a guarantee and therefore did not give rise to an...

In Anglian Water Services v HMRC [2018] UKUT 431 (27 December 2018), the UT found that HMRC had established the defence of unjust enrichment against a claim for repayment of VAT. Anglian Water was appointed as a water and sewerage undertaker for the...

In HMRC v Greenisland Football Club [2018] UKUT 440 (18 December 2018), the UT found that the FTT had been wrong to find that a clubhouse qualified as ‘village hall or similar building’ (VATA 1994 Sch 8 Group 5 item 2 note 6) but found that its...

In Supaglazing v HMRC [2018] UKFTT 712 (10 December 2018), the FTT found that discovery assessments issued by HMRC were valid as the taxpayer had been careless (FA 1998 Sch 18). Mrs Jones was the majority shareholder, company secretary and a director...

In M Redman v HMRC [2018] UKFTT 714 (11 December 2018), the FTT found that a taxpayer had a reasonable excuse for non-compliance with a notice to file a return. Mr Redman is an evangelical Christian who earns his living as a self-employed...

Our pick of this week's cases   In BlackRock Investment Management v HMRC [2018] UKUT 415 (20 December 2018), the Upper Tribunal (UT) found that financial technology services provided to portfolio managers could ‘in principle’ benefit from the...

In Ball UK Holdings v HMRC [2018] UKUT 407 (10 December 2018), the UT upheld the FTT’s finding that the company had not changed its functional currency according to GAAP. Ball UK Holdings (Ball UK) is a UK intermediate holding company indirectly...

In D Sinclair v HMRC [2018] UKFTT 740 (17 December 2018), the FTT found that Mr Sinclair had not created a bare trust for the benefit of a claimant who was seeking damages from him, so that post-cessation trade relief (PCTR) under ITA 2007 s 96 was...