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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.

No landfill tax disposal from licence revocation and dissolution of permit-holder
Income tax and VAT assessments: In J Smith v HMRC [2026] UKFTT 663 (TC) (6 May), the FTT upheld HMRC’s income tax and VAT assessments and most penalties, while reducing the quantum and cancelling failure-to-file penalties where notices to file had...
Individual match contracts were not contracts of employment
Statutory residence: transit exemption and exceptional circumstances
HMRC’s unreasonable conduct not sufficiently unreasonable for indemnity costs
Discovery, debt assignment, distribution and penalties: In S Thomas v HMRC [2026] UKFTT 627 (TC) (24 April), the FTT decided that when the company assigned to its controlling shareholder a debt of £2.1m owed to the company by a third party, the...
DTT anti-abuse provision did not deny UK withholding exemption  
EBT was not remuneration
Invalid discovery assessment concerning failed SDLT scheme.
Dwelling for SDLT purposes: In Shinebrook Ltd v HMRC [2026] UKFTT 602 (TC) (16 April), the FTT ruled that Multiple Dwellings Relief (MDR) from SDLT was not available in relation to the purchase of a former commercial property, on which planning...
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