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First tier Tribunal
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First tier Tribunal
FIRST-TIER-TRIBUNAL
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Tanja Velling (Slaughter and May) reviews a significant FTT decision in
which the taxpayers were denied interest deductions on a loan created in an
intra-group reorganisation under the unallowable purpose rule.
Generator Power Ltd v HMRC
Costs refused because HMRC’s behaviour was not unreasonable.
Alternative dispute resolution and mediation
Adam Craggs
Liam McKay
We are likely to see a consistent increase in the use of mediation in tax
disputes. Adam Craggs and Liam McKay (RPC) explain when and how it is
in the taxpayer’s interests.
Collins Construction Ltd v HMRC
FTT rejects HMRC’s interpretation of contracted out expenditure in R&D rules.
M Murphy and another v HMRC
FTT finds that sub-sale avoidance scheme failed.
Capital allowances: a question of design?
Paul Farey
Paul Farey (AECOM) considers the impact of the Upper Tribunal’s ruling in
the
Gunfleet Sands
case.
G Ives v HMRC
Property transactions not taxable and
PPR available.
Carelessness and the requirement of causation
Ben Blades
Recent cases have diverged on the question of whether HMRC must establish that carelessness caused a loss of tax, writes Ben Blades (Gray’s Inn Tax Chambers).
Lead cases in the tax tribunal: the rule 18 procedure
Anastasia Nourescu
Matthew Greene
Matthew Greene and Anastasia Nourescu (Stewarts) explain what the rule 18 lead case procedure is, review recent case law clarifying its scope and set out a few practical tips for advisers.
Private client review for March 2023
Hriday Munim
Edward Reed
Two victories for HMRC over claims for SDLT relief and another couple of wins in relation to discovery assessments, are among the developments reviewed by Edward Reed and Hriday Munim (Macfarlanes).
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EDITOR'S PICK
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
1 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
2 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
3 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
4 /7
2024: that was the year that was
Jemma Dick
5 /7
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
6 /7
The tractor tax
Stuart Maggs
7 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
The tractor tax
Stuart Maggs
NEWS
Read all
HMRC manual changes: 7 February 2025
US ‘rejects very nature’ of UN tax talks
HMRC consulting on MTT and DTT draft guidance
HMRC data-collection powers
Retained EU law: further changes
CASES
Read all
M Ashley v HMRC
AAA Oriental Ltd v HMRC
Other cases that caught our eye: 7 February 2025
Bryan Robson Ltd v HMRC
Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC
IN BRIEF
Read all
Themes in UK corporate tax disputes for 2025 (and beyond)
JVs and the top-up taxes: does HMRC’s draft guidance bring clarity?
Reflections on the Budget fallout – three months on
BlueCrest: the CA ruling on Condition B
Tweaking the Temporary Repatriation Facility
MOST READ
Read all
Tweaking the Temporary Repatriation Facility
Bryan Robson Ltd v HMRC
ScottishPower: payments under settlement agreements
Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC
Finance Bill amended, but further changes expected