APPEALS209CA89E-4112-4CDC-B8DB-D791CE3CF498

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

HMRC application to set aside barring order refused

Court of Appeal considers burden of proof in penalty appeals 

FTT grants HMRC’s costs application

Judicial review determining tax residency: K (oao R Houldsworth) v HMRC [2025] EWHC 2848 (Admin) (4 November) revisits an issue which many people might have thought had gone away: the extent to which the (former) IR20 booklet can be relied on when...