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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.
Other cases that caught our eye: 23 May 2025
Trade losses not recoverable: Losses made in a trade carried on by a sole trader can be set against his or her other income. However, relief is not available where the trade is not carried on a commercial basis with a view to profit. C Macdonald v...
R (on the application of Rettig Heating Group UK Ltd (in liquidation)) v HMRC
Upper Tribunal decides that HMRC lawfully refused late claim under SP 5/01
Accuro Trust (Switzerland) SA v HMRC
Foreign property added to excluded property settlement when deemed domiciled is not relevant property
NHS Ayrshire & Arran Health Board v HMRC
Secure mental health unit for children did not qualify for zero-rating
Realbuzz Group Ltd v HMRC
Discovery assessment invalid
Other cases that caught our eye: 16 May 2025
Principal private residence relief available: R Eyre and another v HMRC[2025] UKFTT 461 (TC) (23April) is not the first case on CGT private residence relief where HMRC have challenged availability of the relief on the basis that there has been...
A Beard v HMRC
Court of Appeal finds that distributions debited to company’s share premium account were dividends that were not capital in nature
JD Wetherspoon plc v HMRC
Cider excluded from reduced VAT rate for hospitality and tourism
Roseline Logistics Ltd v HMRC
Agent liability to pay VAT on imports
Other cases that caught our eye: 9 May 2025
Strike out of appeal after failure to cooperate: J Firth v HMRC [2025] UKFTT 428 (TC) (15 April) is a long decision on whether the FTT should accede to HMRCs request to strike out an appeal. This was on the basis that the taxpayer had failed...
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
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Mandatory agent registration: what we know so far
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Permanent Establishment reform: what has changed, who is affected and why does it matter?
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Share reorganisations: new anti-avoidance rules explained
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Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
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Call for evidence: phase out of remaining ACT regime
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HMRC v C Brzezicki
J Hosking v HMRC
L Rowland & Co (Retail) Ltd v HMRC
Other cases that caught our eye: 27 March 2026
Muller UK and Ireland Group LLP and others v HMRC
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Provisions
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MOST READ
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J Hosking v HMRC
Exceptional circumstances – but which way?
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