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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.

Termination payment: In Mrs A v HMRC [2022] UKFTT 421 (TC) (14 November 2022), the taxpayer agreed a compromise settlement with her employer for a sum in excess of 1m. A relatively small amount was agreed as non-taxable compensation for injury...
Out of time appeal rejected, despite strong legal case
Customs declarations determine which party is liable for import VAT
Reasonable excuse: N Futcher v HMRC [2022] UKFTT 401 (TC) (3 November 2022) makes rather sad reading. The appeal was against a late return penalty: not the standard penalty for late submission of a self-assessment return but the much higher penalty...
Works performed by public authority not carried out in the course of an economic activity 
Court of Appeal disallows management expenses as capital
Appealing penalties for deliberate or fraudulent behaviour: P Dowds v HMRC [2022] UKFTT 402 (TC) (3 November 2022) considers no particular technical difficulties but nonetheless has a few points of interest. Assessments for multiple years to income...
Reinstatement of appeal refused
Ramsay applied to deny loss arising under gilt strips scheme
CJEU rules on state aid in Fiat case
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