CASES

Carrying on a trade?: N Henderson v HMRC [2023] UKFTT 281 (TC) (8 March 2023), is a classic case of whether an individual buying and selling shares is carrying on a trade or merely making investments. As so often happens the taxpayer wanted to be...

Tax relief denied for amortisation debits accrued on assets transferred to LLP 

Group relief

Services invoiced and paid after leaving a VAT group

Discovery assessments where agent was not authorised to file returns 

Deliberate behaviour: In CPR Commercials Ltd v HMRC [2023] UKUT 61 (TCC) (7 March 2023), the UT upheld the taxpayer’s appeal against the FTT’s decision that its failure to correctly account for VAT was deliberate. The taxpayer zero-rated its...

CJEU upholds validity of EU law in OnlyFans case

HMRC ordered to issue closure notice

Discovery assessment issued during enquiry window was invalid

Group relief and EU lawdevelopment: In Volkerrail Plant Ltd v HMRC [2023] EWCA Civ 210, the Court of Appeal (CA) held that ICTA 1988 s 403D(1)(c), a provision in the UKs group relief rules in force at the relevant time, was...