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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 new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Broad opposition to proposed ‘reckless statements’ tax offence
GfC7 points to disclosure facility for late TP corrections
Options explored for simplifying offshore anti-avoidance rules
CIOT calls for urgent changes on IHT on pensions
Normal minimum pension age protection consultation
CASES
Read all
HMRC v G Quillan
Perenco UK Ltd v HMRC
HMRC v C Candy
Property 118 Ltd and another v HMRC
Ten cases shaping tax practice in 2026
IN BRIEF
Read all
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
Funding the business
HMRC’s annual report for 2025/26
MOST READ
Read all
Tax Journal thanks its July 2026 authors
Property 118 Ltd and another v HMRC
Perenco UK Ltd v HMRC
When is a trustee not a trustee?
The end of offshore execution on secondary transactions