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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: 6 December 2024
Film tax relief: In C Hoyle and others v HMRC [2024] UKFTT 1060 (TC) (26November), the taxpayers took part in film tax schemes under which they invested in LLPs which leased film rights. Their investments were largely funded by loans and the...
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
Supreme Court denies enterprise zone allowances.
The Tower One St George Wharf Ltd v HMRC
UT denies SDLT group relief because of tax avoidance main purpose.
HMRC v The Taxpayer and others
Taxpayer loses right to confidentiality.
R (oao Refinitiv Ltd and others) v HMRC
Court of Appeal dismisses DPT judicial review.
Generator Power Ltd v HMRC
Costs refused because HMRC’s behaviour was not unreasonable.
Other cases that caught our eye: 22 November 2024
Tax advantage to remuneration arrangements: FA 2022 gives HMRC the power to publish information where (broadly) it suspects that the main benefit of arrangements is to obtain a tax advantage. In K (oao Payeworx Ltd) v HMRC [2024] EWHC 2842 (Admin)...
Syngenta Holdings Ltd v HMRC
Unallowable purpose rule applied to deny deductions on intra-group lending.
The Executors of K Beresford v HMRC
Business property relief refused for serviced offices
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
VAT treatment of health services supplied to local authorities.
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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
,
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
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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
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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
IN BRIEF
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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
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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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