APPEALS209CA89E-4112-4CDC-B8DB-D791CE3CF498

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’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

Application to recategorise information notice appeal as complex refused

SDLT appeal against closure notice:A Sajedi and others v HMRC [2026] UKUT 101 (TCC) (24 September 2025) concerned an arrangement which was designed to obtain the relief from higher rates of SDLT available where a person replaces his or her main...

Discovery assessments out of time