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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: 7 March 2025
Disclosure of documents in loan charge case: K (oao Airedale Chemical Company Ltd) v HMRC [2025] UKUT 65 (TCC) (20 February 2025) is another case arising from the controversy about the loan charge. Following the Morse review HMRC established a scheme...
The executors of L Elborne deceased and others v HMRC
Upper Tribunal finds home loan scheme effective.
Chelsea Cloisters Management Ltd v HMRC
FTT had no jurisdiction to apply extra statutory concession.
HMRC v Asset House Piccadilly Ltd
FTT considers meaning of ‘promoter’ in DOTAS regime.
Other cases that caught our eye: 28 February 2025
Adequacy of reasons given by FTT: In H Rafferty v HMRC [2025] UKUT 63 (TCC) (19 February), the taxpayer was given limited permission to appeal to the UT against closure notices, assessments and penalties. The decision of the UT in rejecting the...
A Taxpayer v HMRC
Court of Appeal decides moral obligations can be part of ‘exceptional circumstances’ for statutory residence test.
HMRC v Royal Bank of Canada
Supreme Court confirms DTT did not give UK taxing rights over oil payments.
R (oao) Anglia Ruskin Students’ Union v HMRC
What is a bar?
B Joseph v HMRC
Scope of employee taxpayer information notice restricted.
Lloyds Asset Leasing Ltd v HMRC
FTT denies cross-border group relief claim on main purpose grounds.
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401
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
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
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
NEWS
Read all
Tax Journal authors for March
New reporting requirements for close company payments proposed
Lords amendments to NICs Bill rejected
Call for evidence: phase out of remaining ACT regime
Call for evidence: business systems integration
CASES
Read all
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
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
J Hosking v HMRC
Countrywide Partners Ltd v HMRC
Exceptional circumstances – but which way?
Muller UK and Ireland Group LLP and others v HMRC
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