CLOSURE-NOTICE

Closure notice charging fee to corporation tax as a chargeable gain

Repayment of withholding tax: Skatteforvaltningen v Solo Capital Partners LLP [2025] EWHC 2364 (Comm) (2 October) is the long-awaited judgment in the case under which the Danish tax authorities are suing various individuals and firms in respect of...

Scope of closure notices

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 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).

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...

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...

Adam Craggs and Liam McKay (RPC) provide a refresher guide.

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...

Mixed-use SDLT appeal failed