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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.
M R Currell Ltd v HMRC
UT sets aside FTT decision on treatment of EBT arrangements.
NHS Mid & South Essex ICB and others v HMRC
Element of redress payments constitutes interest.
Chemidex Generics Ltd v HMRC
Appeal allowed on IP valuation and amortisation period.
FRF (South Wales) Ltd v HMRC
Business premises renovation allowance claim succeeds.
Other cases that caught our eye: 10 January 2025
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...
C Hoyle and others v HMRC
Sale of LLP capital accounts not subject to income tax.
Other cases that caught our eye: 13 December 2024
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...
Five key cases of 2024
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...
Stage One Creative Services Ltd v HMRC
R&D claim succeeds before FTT.
R Grint v HMRC
Sale of occupation income tax charge
upheld.
Go to page
of
404
EDITOR'S PICK
Spare us the cUTTer
Nick Thornton
1 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
2 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
3 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
4 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
5 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
6 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
7 /7
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
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
NEWS
Read all
Foreign Permanent Establishment exemption to be made mandatory
Chancellor announces package of road fuel measures
Quarterly advisory fuel rates published
New Isle of Man social security agreement signed
Streeting proposes CGT equalisation in ‘wealth tax’ plan
CASES
Read all
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
H Gwyn-Jones v HMRC
Other cases that caught our eye: 29 May 2026
HC-One No 1 Ltd v HMRC
IN BRIEF
Read all
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
The growing problem of the personal allowance phase down
Situs: loan notes
MOST READ
Read all
HC-One No 1 Ltd v HMRC
When Homer nods: the rise of the Inco principle in tax
Take 3.9 TV Partnership and others v HMRC
The growing problem of the personal allowance phase down
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