CASES

Scottish Land and Buildings Transaction tax: In Alexander Benjamin Associates Ltd v Revenue Scotland [2024] FTSTC 11 (23 December 2024) , the Scottish FTT dismissed the taxpayers appeal against a decision by Revenue Scotland to impose...

High Court permits rescission of sub-trust appointments saving IHT for EBTs caught by income tax avoidance rules.

UT sets aside FTT decision on treatment of EBT arrangements.

Element of redress payments constitutes interest.

Appeal allowed on IP valuation and amortisation period.

Business premises renovation allowance claim succeeds.

Carried forward losses: In Blackfriars Hotel (UK) Holdings Ltd v HMRC [2024] UKFTT 1095 (TC) (6 December 2024), the FTT considered an appeal by the taxpayer against a decision of HMRC to deny the use of carried-forward non-trading loan relationship...

Sale of LLP capital accounts not subject to income tax.

Compensation exemption did not apply: The one thing about tax that everybody knows is that a tax-free payment of up to 30,000 can be paid as compensation for loss of office. As Simrajsar Ltd and another v HMRC [2024] UKFTT 1072...

1. Unallowable purpose: BlackRockThis year saw the publication of three judgments from the Court of Appeal (CA) affirming a wide application of the loan relationships unallowable purpose test. The first of these was BlackRock Holdco 5, LLC v HMRC...