CASES

Court of Appeal considers burden of proof in penalty appeals 

Licence of client list was an intangible fixed asset for CT purposes

VAT on promotional photography costs

Costs awarded because of taxpayer’s unreasonable conduct: In HMRC v Mattu [2025] UKUT 410 (TCC) (16 December 2021), the UT awarded HMRC £5,000 in costs under rule 10(3)(d) of the UT rules (SI 2008/2698), confirming that there is no requirement for a...

VAT on professional fees to assist with sale of subsidiary is not deductible, Supreme Court rules

Goodwill amortisation: continuity of business defeats relief 

SDLT anti-avoidance provisions trump connected companies market value rule exception 

Mixed-use SDLT rates applied to the acquisition of an apartment with a basement storage unit

Burden of proof and civil penalties: The Court of Appeal inHMRC v Sintra Global Inc and another[2025] EWCA Civ 1661(18 December 2025) decided in favour of HMRC, holding that the UT had made various errors of law, in particular, by...

Choosing five cases of the year is always an exercise in omission. This selection is not a league table of importance so much as a snapshot of where the courts and tribunals have set a marker on some key topical issues across the tax...