APPEALS

Adequacy of reasons given by FTT: In H Rafferty v HMRC [2025] UKUT 63 (TCC) (19 February), the taxpayer was given limited permission to appeal to the UT against closure notices, assessments and penalties. The decision of the UT in rejecting the...

Appeal allowed on IP valuation and amortisation period.

Taxpayer loses right to confidentiality.

Malcolm Gammie CBE KC

The Supreme Court stands at the head of the UK’s judicial appeals system. Malcolm Gammie CBE KC (One Essex Court) examines when permission to appeal to the Supreme Court is likely to be granted, and considers how taxpayers and HMRC are faring in securing permission.

Upper Tribunal allows HMRC’s IR35 appeal.

High Court strikes out Part 8 loan charge claims.

Dan Williams

Adam Craggs

Adam Craggs and Dan Williams (RPC) consider the various stages involved in an appeal to the First-tier Tribunal and focus on the FTT’s case management powers throughout the process.

Taxpayer’s attempt to avoid full IR35 hearing on previously untested procedural grounds is rejected.

Constantine Christofi

The last in a trilogy of recent Court of Appeal cases on ‘unallowable purpose’ has seemingly extended its ambit yet further, writes Constantine Christofi (EY).

UT dismisses gilt strips scheme appeal.

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