CASES

Each week we report the tax cases that matter. Tax Journal subscribers have unrestricted access to the full archive, covering hundreds of cases.

Farming LLP’s sideways loss relief fails commerciality test

Whether VAT on cost of a car can be recovered

HMRC’s unreasonable conduct justified standard costs

Employee ‘loans’ were taxable earnings: In J Lowry v HMRC [2026] UKFTT 1279 (TC) (3 September), the FTT dismissed the taxpayer’s appeal, finding that substantial interest-free ‘loans’ received through an employee remuneration arrangement were taxable...

Capital repayment by a UK limited company not excluded from Transactions in Securities regime

Loan charge determinations upheld as Ramsay requires genuine economic cost

Entitlement to BADR formed part of the subject matter of closure notice

Whether property was non-residential

UT denies taxpayer costs protection application: In HMRC v J Wardle [2026] UKUT 335 (TCC) (28 August), the UT rejected the taxpayer’s application for protection against an adverse costs order in HMRC’s appeal concerning when his partnership’s trade...

Developer profits were ‘income derived from immovable property’ under DTT so UK retained taxing rights, Upper Tribunal rules

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