CJRS

Determinations concerning the CJRS

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...

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...

CJRS overclaims: Ark Angel Ltd v HMRC [2024] UKFTT 772 (TC) (22 August) is another in the continuing line of cases in which HMRC seek to recover amounts paid out under the CJRS (‘furlough’) scheme. The decision here is highly fact...

Carried interest base cost shift: In N Millican v HMRC [2024] UKFTT 618 (TC) (5 July), the FTT upheld the taxpayer’s appeal that his disposal of an interest in a company did not fall within the special regime in the TCGA 1992 which applies...

Collagen drink not food for VAT purposes: There have seen many cases over the years about the boundaries between cakes and biscuits for VAT purposes but the dispute in Bottled Science Ltd v HMRC [2024] UKFTT 592 (TC) (4 July) was over a more...

UK Finco exemption: In UK and ITV plc v European Commission (Joined Cases T-363/19 and T-456/19) (11 April 2024), Advocate General Medina has opined that the CJEU should set aside the General Court’s judgment and annul the Commission’s...

Calculating CJRS payments: We have seen a number of cases recently concerning the furlough (CJRS) scheme. Most of these have been about whether an employee meets the eligibility requirements. Ark Angel Ltd v HMRC [2023] UKFTT 705 (TC) (4 August 2023)...