CASES

EBTs and penalties for inaccuracies in returns: Delphi Derivatives Ltd v HMRC [2023] UKFTT 722 (TC) (18 August) is the second decision on the Clavis Herald avoidance scheme in recent weeks. The scheme involved an EBT but its structure was...

Share exchange scheme was not the main purpose to avoid CGT

Substantial shareholding exemption not available

Film partnership: £11m loss relief denied

Disadvantageous decision to rely on direct effect of EU law was not a VAT error 

Taxpayer’s carelessness did not result in a loss of tax 

Calculating CJRS payments: We have seen a number of cases recently concerning the furlough (CJRS) scheme. Most of these have been about whether an employee meets the eligibility requirements. Ark Angel Ltd v HMRC [2023] UKFTT 705 (TC) (4 August 2023)...

Corporate exit charges should be payable by instalments.

No error by FTT in applying unallowable purpose rules.

Lead cases, pensions, discovery, reliance on adviser, surcharges for late VAT payment and more.