APPEALS

Philippe Gamito (Baker McKenzie) reviews an Upper Tribunal decision which is likely to shape the way international businesses design in-house outsourcing strategies.

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) review some notable rulings on a range of procedural issues, as well as recent changes to the tribunal rules.

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) review lessons from several important procedural decisions and a successful challenge to HMRC’s approach to subject access requests.

The hardship test

Late appeals: are the decisions in Martland and Katib binding?

SEISS (and AI): In HMRC v M Gunnarsson [2025] UKUT 247 (TCC) (23 July), the taxpayer operated through a personal service company and was therefore ineligible for Coronavirus Self-Employment Income Support Scheme (SEISS). He nonetheless applied for...

No right of appeal against consequential amendments to partners’ returns

LBTT – transition from SDLT: In Archer UK Ltd v Revenue Scotland [2025] FTSTC 10 (10 July), the Scottish FTT upheld the taxpayer’s appeal that the variation and extension of a lease did not constitute a land transaction as the grant of a...

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...

Supreme Court ruling on oil contractor regime

Go to page of 7