CASES

Out of time appeal rejected, despite strong legal case

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

Claim for repayment of SDLT must be within the normal 12-month deadline