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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 granted permission to amend their statement of case 
Late payment of Class 2 NICs allowed: In M Gadsden v HMRC [2026] UKFTT 720 (TC) (14 May), the taxpayer (a barrister working almost exclusively in criminal law) had failed to pay Class 2 NICs between the years 1981 and 2014. This had an impact on his...
Liquidation of parent company to preserve SDLT group relief did not have tax avoidance main purpose
Film production companies payments were allowable deductions
No late payment penalties on reallocation of earlier tax payments
Adjoining property was part of garden for SDLT purposes: Vereley Homes Ltd v HMRC [2026] UKFTT 695 (TC) (12 May) is another failed taxpayer appeal for SDLT mixed-use treatment. The only issue here was whether a separate, fenced plot (the former site...
Penalties: reliance on trusted accountant
Re-litigating the same issue
No landfill tax disposal from licence revocation and dissolution of permit-holder
Income tax and VAT assessments: In J Smith v HMRC [2026] UKFTT 663 (TC) (6 May), the FTT upheld HMRC’s income tax and VAT assessments and most penalties, while reducing the quantum and cancelling failure-to-file penalties where notices to file had...
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