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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.

SDLT MDR denied where planning restriction existed.

Input VAT recovery on supply of land.

Reasonable excuse and reliance on third party: In Xcel Consult Ltd v HMRC [2025] UKFTT 96 (TC) (30 January), the taxpayer was arguing that she had a reasonable excuse defence in her appeal against a VAT surcharge because she had relied on her...

High Court considers subject access rights under UK GDPR in context of tax enquiry.

Sch 36 information notice upheld.

Employee loan arrangements: FS Capital Ltd and others v A Adams and others [2025] EWCA Civ 53 (28 January) is yet another twist in the long saga of employee loan arrangements and their resolution. It is not a tax case as such but will be of interest...

IR35 and image rights.

Arrangements relating to animation project were disqualifying for EIS.

FTT decision on SDLT upheld: C Halstead v HMRC [2025] UKUT 22 (TCC) (15 January) is a decision of the UT refusing an application by the taxpayer to appeal against a decision of the FTT. We are now starting to see publication of the decisions in...

Court of Appeal remits salaried members case to FTT.

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EDITOR'S PICK

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

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

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?

Hotel La Tour: where next for input tax recovery on share disposals?

Rupert Shiers , Laura Hodgson

Mandatory agent registration: what we know so far

Mandatory agent registration: what we know so far

Jane Mellor

Permanent Establishment reform: what has changed, who is affected and why does it matter?

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

The Pillar Two Side-by-Side package: how UK groups should approach compliance

Jack Gifford

Share reorganisations: new anti-avoidance rules explained

Share reorganisations: new anti-avoidance rules explained

Peter Morley , Jamie Robson

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

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

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?

Hotel La Tour: where next for input tax recovery on share disposals?

Rupert Shiers , Laura Hodgson

Mandatory agent registration: what we know so far

Mandatory agent registration: what we know so far

Jane Mellor

Permanent Establishment reform: what has changed, who is affected and why does it matter?

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

The Pillar Two Side-by-Side package: how UK groups should approach compliance

Jack Gifford

Share reorganisations: new anti-avoidance rules explained

Share reorganisations: new anti-avoidance rules explained

Peter Morley , Jamie Robson

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