CASES

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

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...

Late appeal allowed: C Horder v HMRC [2023] UKUT 106 (TCC) (11 May 2023) is an unfortunate case in which an unpaid director of a company, who accepted that he was a patsy for the companys shadow director, found himself liable to...

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