CASES

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

Appeal allowed on IP valuation and amortisation period.

Business premises renovation allowance claim succeeds.

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...

Sale of LLP capital accounts not subject to income tax.

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...

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...

R&D claim succeeds before FTT.

Sale of occupation income tax charge upheld.

FTT holds discrimination settlement payment not taxable.

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...

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