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FOLLOWER-NOTICE
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...
K Pitt v HMRC
Upper Tribunal clarifies application of the follower notice regime.
How binding are FTT decisions?
Oliver Marre
Oliver Marre (5 Stone Buildings) considers two ways in which decisions of the FTT can influence the results of later cases.
20 questions: HMRC’s civil and criminal powers
Constantine Christofi
Adam Craggs
A detailed guide by Adam Craggs and Constantine Christofi (RPC).
Back to basics: Accelerated payment notices and follower notices
Sam Wardleworth
Steven Porter
Steven Porter and Sam Wardleworth (Pinsent Masons) provide a refresher guide to these ‘game changing’ regimes.
When is a defective HMRC notice invalid?
Sam Wardleworth
Steven Porter
Steven Porter and Sam Wardleworth (Pinsent Masons) examine recent cases that suggest a growing reluctance on the part of the courts to declare notices invalid for minor HMRC errors.
Haworth: the Supreme Court’s ruling on follower notices
Ben Elliott
HMRC’s attempts to reverse the limitations imposed by the Court of Appeal
backfired, as Ben Elliott (Pump Court Tax Chambers) explains.
Private client review for October 2020
Andrew Goldstone
Katherine Forster
Andrew Goldstone and Katherine Forster (Mishcon de Reya) review recent
tax developments affecting private clients.
Locke: Court of Appeal again quashes follower and accelerated payment notices
Geoff Lloyd
Geoff Lloyd (EY) discusses the impact of a second Court of Appeal decision in six months that has overturned follower and accelerated payment notices.
Haworth: Court of Appeal quashes follower and accelerated payment notices
Sabina Margulies
Sabina Margulies (Lexis®PSL Tax) reviews lessons from the Court of Appeal judgment.
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3
EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
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Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CBAM: technical guidance on emissions reporting
CASES
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Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others v HMRC
IN BRIEF
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AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
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The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030