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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: 12 July 2024
Interest calculation on restitutionary payment: Test claimants in the franked investment income group litigation v HMRC [2024] EWHC 1671 (Ch) (18 June 2024) is another episode in the saga of the compatibility of the UKs regime for the taxation...
HMRC v Altrad Services Ltd and another
CA overturns UT decision in ‘magic’ capital allowances avoidance scheme.
UK Care No. 1 Ltd v HMRC
Part of loan relationship loss disallowed as referable to period of non-UK tax residence.
J Wardle v HMRC
Entrepreneurs’ relief claim allowed.
Other cases that caught our eye: 5 July 2024
Amortisation of goodwill: AlthoughArmour Veterinary Group Ltd v HMRC [2024] UKFTT 539 (TC) (13 June) is a case about corporation tax relief for the amortisation of goodwill it will be of more interest to partnership practitioners. This is...
P Cox and another v HMRC
Penalties for incorrect BADR claim upheld.
CATS North Sea Ltd v HMRC
Transfer of trade and capital allowances provisions in context of ring fence trade.
Queenscourt Ltd v HMRC
Dip pot formed part of single supply of takeaway food subject to VAT.
Another case that caught our eye: 28 June 2024
Procedure for assessing penalties:IMajid v HMRC [2024] UKFTT 491 (TC) (25 May) is what might be seen as a routine appeal against a penalty determination, but there is one point of general interest. An officer of HMRC had spoken to the...
JTI Acquisition Company (2011) Ltd v HMRC
Court of Appeal affirms a wide application of the loan relationships unallowable purpose test.
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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
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Mandatory agent registration: what we know so far
Jane Mellor
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Permanent Establishment reform: what has changed, who is affected and why does it matter?
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The Pillar Two Side-by-Side package: how UK groups should approach compliance
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Share reorganisations: new anti-avoidance rules explained
Peter Morley
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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
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Call for evidence: phase out of remaining ACT regime
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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
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