CASES

Each week we report the tax cases that matter. Tax Journal subscribers have unrestricted access to the full archive, covering hundreds of cases.

Invalid discovery assessment concerning failed SDLT scheme.

Dwelling for SDLT purposes: In Shinebrook Ltd v HMRC [2026] UKFTT 602 (TC) (16 April), the FTT ruled that Multiple Dwellings Relief (MDR) from SDLT was not available in relation to the purchase of a former commercial property, on which planning...

Capital allowances not available for environmental studies expenditure

Profits arose from oil extraction activities

A reusable container is not necessarily a separate supply

Normal expenditure out of income: JWood v HMRC [2026] UKFTT 589 (TC) (16 April) is the second recent decision, after Hosking [2026] UKFTT 406 (TC) (see Tax Journal, 27 March 2026), on the limits of the IHT exemption for gifts out of income....

Capital allowances: ring fence trades and intra-group transfers

Host employer rules: no control needed for NIC liability.

Share loss relief: S Wilders v HMRC [2026] UKFTT 517 (TC) (1 April) is a claim for share loss relief arising from a failed attempt to recover treasure from the wreck of the ship the Merchant Royal, which sunk in 1641 off Land’s End. Investors...

Government funding held to be consideration for supplies

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