AVOIDANCE-SCHEMES

There will be the usual complaints about the tax burden on working people, but it is very modest compared with the 1960s and 1970s, when the top rate of income tax was still 98%, imposed to pay the USA for the monies lent to us for WW2. There will...

Sinisa Butina

Angela Savin

Angela Savin and Sinisa Butina (KPMG) examine the basis of the Upper Tribunal’s reasoning in Scatola and the broader ramifications for taxpayers seeking certainty and finality to their SDLT affairs.

Ben Elliott

Arthur Wong

The recent cases of Bhaur and JTC illustrate the opportunities and challenges for taxpayers who have misunderstood the tax consequences of a transaction, write Ben Elliott and Arthur Wong (Pump Court Tax Chambers).

Discovery assessments out of time

Burden of proof and civil penalties: The Court of Appeal in HMRC v Sintra Global Inc and another [2025] EWCA Civ 1661 (18 December 2025) decided in favour of HMRC, holding that the UT had made various errors of law, in particular, by...

UT dismisses taxpayers’ appeal against closure notices charging SDLT from failed avoidance scheme.

LLP not trading, so tax deductions and R&D relief denied.

Ramsay argument fails to save taxpayer from £10m tax assessment

Insolvency consequences of a failed avoidance scheme: C Purkiss v T Kennedy and others [2025] EWCA Civ 268 (14 March) is not a tax case but will be of interest to many tax practitioners because it concerns the insolvency consequences of a failed...

Film tax relief: In C Hoyle and others v HMRC [2024] UKFTT 1060 (TC) (26 November), the taxpayers took part in film tax schemes under which they invested in LLPs which leased film rights. Their investments were largely funded by loans and the...

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