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Court of Appeal
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Court of Appeal
COURT-OF-APPEAL
Mainpay Ltd v HMRC
Court of Appeal rejects ‘third option’ for employment contracts, but confirms causal link to carelessness before assessment timeframe can be extended
A Beard v HMRC
Court of Appeal finds that distributions debited to company’s share premium account were dividends that were not capital in nature
A Taxpayer v HMRC
Court of Appeal decides moral obligations can be part of ‘exceptional circumstances’ for statutory residence test.
P Marano v HMRC
Court of Appeal considers validity of automated notices and assessments.
HMRC v Altrad Services Ltd and another
CA overturns UT decision in ‘magic’ capital allowances avoidance scheme.
Back to BlackRock: the Court of Appeal restores order
Helen Buchanan
Sarah Bond
The Court of Appeal judgment restores order, write Sarah Bond and
Helen Buchanan (Freshfields Bruckhaus Deringer).
The VAT review for April 2024
Jo Crookshank
Gary Barnett
Pensions funds, Reemtsma claims and supplies by NHS trusts are among the topics in this month’s VAT review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
M Brown and another v HMRC
Court of Appeal rejects SDLT scheme.
Certainty vs deterrence: the Supreme Court’s approach to anti-avoidance legislation in Fisher
Ben Elliott
The Supreme Court has effectively left it open to future courts to counteract artificial avoidance, writes Ben Elliott (Pump Court Tax Chambers).
Characterising supplies for VAT following Mesto Zamberk
Michael Thomas KC
The characterisation test for VAT has received important clarification from the Court of Appeal, writes Michael Thomas KC (Pump Court Tax Chambers).
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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
Tax Journal authors for December
HMRC manual changes: 12 December 2025
Finance Bill 2026 published
HMRC revise position on VAT grouping and the Skandia judgment
HMRC explain TOMS changes
CASES
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Cases of 2025
Places for People Homes Ltd v HMRC
Executor of P Goudman-Peachey v HMRC
HMRC v M Breen
Other cases that caught our eye: 5 December 2025
IN BRIEF
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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
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Budget 2025 changes to the share exchanges and reorganisation rules
The 2025 loan charge review and Government response: the final chapter?
Tax Journal's 2025 Budget coverage
TSI Instruments and import VAT recovery
Finance Bill 2026 published