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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.

Disregarding carry-back loss claim in closure notice appeal.
CJEU judgment on VAT and fixed establishments.
HICBC and discovery assessment powers: There is no sign of the flow of high income child benefit charge (HICBC) cases drying up. HMRC presumably hoped that the retrospective legislation to reverse the decision in Wilkes [2020] UKUT 150 (TCC), where...
Double tax treaty did not confer UK taxing rights to oil royalty payments.
Input tax on free pandemic PPE denied as not directly linked to a taxable supply.
CJRS denied for employees omitted from RTI return.
Carry back of corporation tax losses: In Civic Environmental Systems Ltd v HMRC [2023] EWCA Civ 722 (26 June 2023), the taxpayer company had made a claim to carry back corporation tax losses to a previous accounting period (which generated a...
Information notice upheld relating to property transactions in the UK.
Penalties upheld despite related VAT assessments being out of time. 
Late filing penalties re ATED return.
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