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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.
L v HMRC
FTT holds discrimination settlement payment not taxable.
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
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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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