APNS

Glyn Edwards (MHA) examines an apparent increase in HMRC strike-out applications and why many are failing to clear the tribunal’s high threshold.

Follower notices and corrective action: C Maguire v HMRC [2026] UKFTT 929 (TC) (18 June) is a rare example of a taxpayer succeeding in an appeal against a penalty for failing to take corrective action after receiving a follower notice. The taxpayer...

Dwelling for SDLT purposes: In Shinebrook Ltd v HMRC [2026] UKFTT 602 (TC) (16 April), the FTT ruled that Multiple Dwellings Relief (MDR) from SDLT was not available in relation to the purchase of a former commercial property, on which planning...

JR challenge to APNs refused: In R (oao Adviser Business Solutions Ltd and others) v HMRC [2025] EWHC 1641 (Admin) (30 June), the HC refused permission to challenge Accelerated Payment Notices (APNs), holding that where HMRC have already formed...

Disguised remuneration schemes, end users and judicial review: It is now accepted that most, if not all, disguised remuneration schemes involving the making of loans to employees via an employee benefit trust do not work and that the arrangements...

SDLT multiple dwellings relief: H Gabra and another v HMRC [2025] UKFTT 399 (TC) (4 April) is one of two cases reported this week on multiple dwellings relief (MDR) – between them they form a good case study on the scope of the relief. In...

Employee loan arrangements: FS Capital Ltd and others v A Adams and others [2025] EWCA Civ 53 (28 January) is yet another twist in the long saga of employee loan arrangements and their resolution. It is not a tax case as such but will be of interest...

No hardship with VAT assessment: A taxpayer wishing to appeal to a tribunal against a VAT assessment must either pay the disputed tax up front or apply to HMRC or the tribunal for permission not to pay the assessment on grounds of hardship. SC...

Upper Tribunal dismisses challenges to accelerated payment notices.