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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.

The executors of L Elborne deceased and others v HMRC premium
Upper Tribunal finds home loan scheme effective.
26 February 2025
Chelsea Cloisters Management Ltd v HMRC premium
FTT had no jurisdiction to apply extra statutory concession.
26 February 2025
HMRC v Asset House Piccadilly Ltd premium
FTT considers meaning of ‘promoter’ in DOTAS regime.
26 February 2025
Other cases that caught our eye: 28 February 2025 premium
Adequacy of reasons given by FTT: In H Rafferty v HMRC [2025] UKUT 63 (TCC) (19 February), the taxpayer was given limited permission to appeal to the UT against closure notices, assessments and penalties. The decision of the UT in rejecting the...
26 February 2025
A Taxpayer v HMRC premium
Court of Appeal decides moral obligations can be part of ‘exceptional circumstances’ for statutory residence test.
19 February 2025
HMRC v Royal Bank of Canada premium
Supreme Court confirms DTT did not give UK taxing rights over oil payments.
19 February 2025
R (oao) Anglia Ruskin Students’ Union v HMRC premium
What is a bar?
19 February 2025
B Joseph v HMRC premium
Scope of employee taxpayer information notice restricted.
19 February 2025
Lloyds Asset Leasing Ltd v HMRC premium
FTT denies cross-border group relief claim on main purpose grounds.
12 February 2025
S Fitzgerald and another v HMRC premium
SDLT MDR denied where planning restriction existed.
12 February 2025
EDITOR'S PICKstar
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T Bunting v HMRC
21 October 2026
J Smith v HMRC
14 October 2026
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