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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.
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...
HMRC v T Suterwalla and another
Paddock did not form part of grounds of dwelling for SDLT purposes.
Jelly Vine Productions Ltd v HMRC
Taxpayer’s attempt to avoid full IR35 hearing on previously untested procedural grounds is rejected.
S Sangha v HMRC
FTT varies information notice.
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...
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411
EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Welsh tax Bill proposes repayment powers and LTT changes
Voluntary payrolling extended to accommodation and loans
Clarification sought on IHT exemption for charitable trusts
‘No separate VAT rules for cryptoassets’, HMRC say
CBAM: draft default emissions values published
CASES
Read all
ScottishPower (SCPL) Ltd and others v HMRC
T Bunting v HMRC
Brants Bridge Ltd and another v HMRC
Other cases that caught our eye: 23 October 2026
J Smith v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
Side-by-Side: four scenarios for 2030
Incorporating an LLP: direct tax considerations