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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.
HMRC v Vermilion Holdings Ltd
Supreme Court rules on deeming provision for share options.
Dollar Financial UK Ltd v HMRC
Taxpayer’s attempt to change VAT group joining date denied.
MyPay v HMRC
Application to amend grounds of appeal refused.
R (o.a.o Refinitiv Ltd and others) v HMRC
No inconsistency between DPT notices and terms of advance pricing agreement.
Other cases that caught our eye 3 November 2023
Accounting standards and taxable profit: In Hart St Maltings Ltd v HMRC [2023] UKFTT 860 (TC) (12 October 2023), a company was a small property developer that had purchased a building for conversion into two separate properties and at the end of the...
JPMorgan Chase Bank, NA v HMRC
Services supplied within an investment banking group were a single supply subject to VAT
United Biscuits (UK) Ltd v HMRC
Biscuit was partly covered by chocolate and therefore subject to VAT
Greenwich Contracts Ltd v HMRC
DOTAS scheme reference number properly allocated to umbrella company
S Suttle and other v HMRC
Deliberate inaccuracy penalties could not be transferred to directors of umbrella company
HMRC v M Breen
Upper Tribunal restores appeal strike out
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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
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Welsh tax Bill proposes repayment powers and LTT changes
Voluntary payrolling extended to accommodation and loans
Clarification sought on IHT exemption for charitable trusts
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CASES
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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
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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
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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