APPEALS

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

HMRC permission to appeal against case management decisions refused

Closure notices relating to a claim for share loss relief were validly made 

FTT warning over the dangers of using AI

Trade losses not recoverable: Losses made in a trade carried on by a sole trader can be set against his or her other income. However, relief is not available where the trade is not carried on a commercial basis with a view to profit. C Macdonald v...

Discovery assessment invalid