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A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
David Haughey
David Haworth and David Haughey (Freshfields) examine the implications of the Court of Appeal’s decision for businesses which are potentially within the scope of the UK’s salaried member rules.
Other cases that caught our eye: 31 January 2025
FTT decision on SDLT upheld: C Halstead v HMRC [2025] UKUT 22 (TCC) (15 January) is a decision of the UT refusing an application by the taxpayer to appeal against a decision of the FTT. We are now starting to see publication of the decisions in...
HMRC v BlueCrest Capital Management (UK) LLP
Court of Appeal remits salaried members case to FTT.
Global by Nature Ltd v HMRC
What is a sports drink?
Tax and the City review for January 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated
guidance on share exchanges.
Other cases that caught our eye: 17 January 2025
Scottish Land and Buildings Transaction tax: In Alexander Benjamin Associates Ltd v Revenue Scotland [2024] FTSTC 11 (23 December 2024) , the Scottish FTT dismissed the taxpayer’s appeal against a decision by Revenue Scotland to impose...
FRF (South Wales) Ltd v HMRC
Business premises renovation allowance claim succeeds.
Other cases that caught our eye: 10 January 2025
Carried forward losses: In Blackfriars Hotel (UK) Holdings Ltd v HMRC [2024] UKFTT 1095 (TC) (6 December 2024), the FTT considered an appeal by the taxpayer against a decision of HMRC to deny the use of carried-forward non-trading loan relationship...
C Hoyle and others v HMRC
Sale of LLP capital accounts not subject to income tax.
Other cases that caught our eye: 13 December 2024
Compensation exemption did not apply: The one thing about tax that ‘everybody knows’ is that a tax-free payment of up to £30,000 can be paid as compensation for loss of office. As Simrajsar Ltd and another v HMRC [2024] UKFTT 1072...
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15
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Staggered roll-out for mandatory tax adviser registration
Consultation on proposed UK corporate re-domiciliation regime
Cryptoassets taxation: stablecoins
Administrative change to CIR rules
NIC regs mirror tax changes
CASES
Read all
HMRC v Colchester Institute Corporation
HMRC v Boehringer Ingelheim Ltd
R (oao Rokos) v HMRC
Other cases that caught our eye: 10 April 2026
HMRC v C Brzezicki
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
J Hosking v HMRC
L Rowland & Co (Retail) Ltd v HMRC
Consultation tracker
Case watch
Other cases that caught our eye: 27 March 2026