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Closure notice
Home
Closure notice
CLOSURE-NOTICE
W Tinkler v HMRC
Scope of closure notices
Other cases that caught our eye: 24 January 2025
Host employer regulation and control test: Odfjell Technology (UK) Ltd v HMRC [2025] UKFTT 28 (TC) (9 January) is the third recent case on the operation of the host employer regulations. These apply (broadly) where somebody is employed by an offshore...
The sale of occupational income provisions following Grint
Oliver Marre
The
Grint
case illustrates that HMRC may use the sale of occupational income provisions in even vanilla cases of tax planning, writes Oliver Marre (5 Stone Buildings).
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...
Other cases that caught our eye: 5 July 2024
Amortisation of goodwill: Although Armour Veterinary Group Ltd v HMRC [2024] UKFTT 539 (TC) (13 June) is a case about corporation tax relief for the amortisation of goodwill it will be of more interest to partnership practitioners. This is...
Back to basics: Closure notices and the appeals process
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) provide a refresher guide.
Other cases that caught our eye: 17 May 2024
Post-cessation trade relief/notice of enquiry into return: There are two distinct aspects to A Dennison v HMRC [2024] UKFTT 364 (TC) (2 May 2024). The substantive issue is whether or not the taxpayer was entitled to claim relief under the...
J Harjono and another v HMRC
Mixed-use SDLT appeal failed
Acorn Venture Ltd v HMRC
Capital allowances on camping pods.
Civic Environmental Systems Ltd v HMRC
Disregarding carry-back loss claim in closure notice appeal.
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The trials and tribulations of interest withholding tax
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,
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Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
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,
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The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
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