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Avoidance schemes
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Avoidance schemes
AVOIDANCE-SCHEMES
HMRC v Altrad Services Ltd and another
CA overturns UT decision in ‘magic’ capital allowances avoidance scheme.
S Clipperton and another v HMRC
Court of Appeal confirms that dividend replacement scheme failed.
Other cases that caught our eye: 26 January 2024
BADR and trusts:Trustees of the Peter Buckley Settlement v HMRC [2024] UKFTT 29 (TC) (4 January 2024) emphasises an important point about business asset disposal relief and trusts. A trust can obtain relief on a disposal of a qualifying asset (in...
Other cases that caught our eye: 28 July 2023
Petroleum revenue tax (PRT) and subsidiary argumentIn HMRC v Perenco UK Ltd [2023] UKUT 169 (TCC) (19 July 2023), the UT dismissed HMRC's appeal against the FTT decision. Consequently, expenditure incurred by the taxpayer during the relevant period...
Bhaur: mistake cannot unwind artificial avoidance scheme
Michael Avient
The Court of Appeal judgment in
Bhaur
provides a salutary lesson to those considering artificial tax avoidance schemes, writes Michael Avient (Temple Tax Chambers).
The smoke and mirrors of tax avoidance
Tom Wallace
It is important to look at any tax planning arrangement in the round and not simply the marketing material, Tom Wallace (WTT Consulting) explains.
Purpose and logic: Dunsby as a very modern tax case
Oliver Marre
Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005.
Ingenious Film Partners in the Court of Appeal: lights, camera, action!
Heather Self
Hannah Hurley
Heather Self and Hannah Hurley (Blick Rothenberg) examine the key points and the broader implications of the recent Court of Appeal decision.
Private client review for January 2021
Edward Reed
Claire Tilbrook
Edward Reed and Claire Tilbrook (Macfarlanes) provide this month’s private client update.
VAT: from VADR to DOTAS
Etienne Wong
Etienne Wong (15 Old Square) discusses the new disclosure regime for tax avoidance schemes involving VAT to be introduced by the Finance Act 2017.
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 9 January 2026
Agreement reached on Pillar Two ‘side-by-side’ package
Late change lifts BPR/APR cap
New guidelines on imported hybrid mismatch rules
VAT treatment of supplies of temporary medical staff
CASES
Read all
HMRC v Hotel La Tour Ltd
County Insurance Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
R Sehgal v HMRC
Other cases that caught our eye: 9 January 2026
IN BRIEF
Read all
TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
MOST READ
Read all
HMRC manual changes: 12 December 2025
Agreement reached on Pillar Two ‘side-by-side’ package
Cases of 2025
The Tower One St George Wharf Ltd v HMRC
Consultation tracker