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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.

Relevance of criminal conviction to an appeal against an assessmentIn S Munir v HMRC [2021] EWCA Civ 799 (26 May 2021), the Court of Appeal found that the FTT had erred in its decision not to strike out the appellant's case because it had failed to...
Burden of proof on HMRC assessments
Supreme Court rules on Ramsay and business rates
Guarantee rights in a company are not shares
Court of Session finds for HMRC on disapplication of the option to tax
Costs in complex category caseIn Roger Preston Group Ltd v HMRC [2021] UKFTT 132 (TC) (4 May), the FTT: (i) rejected the appellant’s argument that its costs (to be paid by HMRC as the appellant was the successful party in the substantive proceedings)...
Supreme Court finds taxpayer had not made deliberate inaccuracy, but dismisses concept of staleness
Entrepreneurs’ relief claim failed where trade not yet started
State aid: Luxembourg wins Amazon but loses in Engie
Tax avoidance is deliberate behaviourIn A Outram and another v HMRC [2021] UKFTT 126 (TC) (27 April 2021), the taxpayers who knowingly entering into an avoidance scheme were found to have acted deliberately with a view to claiming non-existent losses...
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