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ASSESSMENTS
The 2025 loan charge review and Government response: the final chapter?
David Pett
All but one of the loan charge review’s ‘hard’ recommendations have been
accepted. David Pett (Temple Tax Chambers) assesses both the review and
the Government’s response – and considers the implications for affected
taxpayers and the new settlement opportunity.
J Nuttall and another v HMRC
No landfill tax disposal from licence revocation and dissolution of permit-holder
Tax Administration Framework Review: dull sounding, but far reaching
Daniel Lusted
Daniel Lusted (BDO) examines what’s being proposed.
Other cases that caught our eye: 15 November 2024
SDLT assessment and closure notice: The Wool House Ltd v HMRC [2024] UKFTT 997 (TC) (30 October) is quite an administrative tangle. The taxpayer paid SDLT on the normal single-property basis but then put in an overpayment relief claim, on the basis...
Rebel without a causal link: HMRC’s position on proving carelessness
Sophie Rhind
Victoria Braid
Mainpay
should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
Other cases that caught our eye: 11 October 2024
R&D tax credits denied: In Strictly Money Ltd v HMRC [2024] UKFTT 866 (TC) (20 September), the judge dismissed the entire R&D claim on the basis that ‘no meaningful work’ was done in respect of the £1.4m expenditure on which...
Andrew Quay Hull LLP v HMRC
ADR exit agreement was binding and enforceable.
Go City Ltd v HMRC
Attraction pass was outside the scope of VAT when sold.
P Marano v HMRC
Court of Appeal considers validity of automated notices and assessments.
Other cases that caught our eye: 1 March 2024
No hardship with VAT assessment: A taxpayer wishing to appeal to a tribunal against a VAT assessment must either pay the disputed tax up front or apply to HMRC or the tribunal for permission not to pay the assessment on grounds of hardship. SC...
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EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
Foreign PE exemption becoming mandatory
HMRC v GCH Corporation Ltd and others
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’