APPEALS209CA89E-4112-4CDC-B8DB-D791CE3CF498

Alan Rafferty Ollie Winters Jade Du Berry

The High Court has confirmed that HMRC do not have a veto over restructuring plans. Alan Rafferty, Jade Du Berry and Ollie Winters (Milbank) examine the implications of Waldorf, including HMRC’s constitutional arguments, the treatment of tax losses and the evolving approach to cross-class cram downs.

Glyn Edwards

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

HMRC granted permission to amend their statement of case

No late payment penalties on reallocation of earlier tax payments

HMRC’s unreasonable conduct not sufficiently unreasonable for indemnity costs

Discovery, debt assignment, distribution and penalties: In S Thomas v HMRC [2026] UKFTT 627 (TC) (24 April), the FTT decided that when the company assigned to its controlling shareholder a debt of £2.1m owed to the company by a third party, the...

Capital allowances not available for environmental studies expenditure

Case management directions relating to witness evidence

Whether source of cash was gambling: Anybody who has been involved in tax investigations will have come across situations where the taxpayer explains that cash deposits which exceed his/her declared business receipts have come from gambling winnings....

Stop notice breach: continued scheme operation

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