CASES

SDLT discovery assessment was valid

SDLT sub-sale scheme failed so SDLT return was required

UT confirms failure of film scheme

Court of Appeal confirms share option acquired when granted 

As it’s our final edition of the year, we depart from our usual weekly case coverage and instead highlight some of the lessons from many of this year’s cases – ranging from an (unreported) FTT decision to judgments of the Supreme Court and the CJEU. We haven't covered everything, but we hope this serves as a handy guide to some of the more interesting decisions.

Upper Tribunal rules on automated HMRC notices, trading activities, remittance basis and transactions in securities

Distributions, settlements and transfers of assets abroad

Evidence of usual place of residence for VAT purposes

Film distribution rights schemeDealing with the consequence of investments into film schemes (and related structures) has taken up huge amounts of judicial time and, as the case of T Good v HMRC [2021] UKUT 281 (TCC) (18 November 2021) shows, many...

Reasonable excuseIn Glenthorne Property Services Ltd v HMRC [2021] UKFTT 370 (TC) (18 October), the FTT unsurprisingly found that internet connection failure was not a reasonable excuse for failure to submit a contractor monthly return on time. The...