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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.
Lycamobile UK Ltd v HMRC
Mobile phone plan bundles.
Other cases that caught our eye: 2 August 2024
Court of Appeal rules that automated notices are valid: In PMarano v HMRC [2024] EWCA Civ 876 (26 July), the CA dismissed the taxpayers appeal that the UT erred in holding that FA 2020 s 103 rendered it unnecessary for HMRC to prove the...
Centrica Overseas Holdings Ltd v HMRC
Supreme Court finds advisers’ fees were capital in nature.
HMRC v GE Financial Investments
CA holds that stapled entity not entitled to double tax relief.
A Outram and another v HMRC
UT overturns FTT finding of deliberate behaviour as error of law.
Other cases that caught our eye: 26 July 2024
Carried interest base cost shift: In NMillican v HMRC [2024] UKFTT 618 (TC) (5 July), the FTT upheld the taxpayers appeal that his disposal of an interest in a company did not fall within the special regime in the TCGA 1992 which applies...
Finanzamt T II v S
CJEU confirms that supplies between VAT groups are outside the scope of VAT.
J Woods v HMRC
HICBC assessment was ‘protected’.
The Oaks (Gatley) Ltd v HMRC
FTT dismisses taxpayer’s public law arguments against CIS determinations.
Other cases that caught our eye: 19 July 2024
Collagen drink not food for VAT purposes: There have seen many cases over the years about the boundaries between cakes and biscuits for VAT purposes but the dispute in Bottled Science Ltd v HMRC [2024] UKFTT 592 (TC) (4 July) was over a more...
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405
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
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
NEWS
Read all
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC phase in mandatory payrolling of benefits from April 2027
ATED pre-return banding checks
Coding out winter fuel payment charge
Pensions advisers urge rethink on IHT
CASES
Read all
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
HMRC v GCH Corporation Ltd and others
Barclays Services Corporation and another v HMRC
Other cases that caught our eye: 19 June 2026
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Consultation tracker
Lifeplus Europe Ltd v HMRC
Sintra, Hall and the reshaping of HMRC’s burden of proof
Management rollovers and share-for-share exchange relief
The UK’s tax certainty problem