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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.

Mixed use SDLT claim succeeds
SEIS: D Hamill v HMRC [2023] UKFTT 451 (TC) (23 May 2023)is another in what is now becoming a long line of cases relating to the various coronavirus support measures. The taxpayer, a litigant in person, had applied for and received a payment...
Late filing penalties re ATED return: In Hughes Property Partners Ltd v HMRC [2023] UKFTT 453 (TC) (25 May), the FTT dismissed the taxpayers appeal against late filing penalties charged under FA 2009 Sch 55 for filing of an ATED return eight...
Special circumstances
VAT relief on bad debts
Withholding tax was due on interest paid by UK resident borrower on recurring loans
No legitimate expectation where clearance request was materially inaccurate and misleading
Operation of gross-up provisions
Court of Appeal dismisses claim to unwind avoidance scheme
CJRS: What is the true cost of a social media publication? In this rather sad story, £9,486.38. Glo-Ball Group Ltd v HMRC [2023] UKFTT 435 (TC) (22 May 2023) concerns the coronavirus job protection scheme, under which HMRC would pay 80% of the wages...
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