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Private client review for June 2024
Edward Reed
Clare Wilson
A new Finance Act and several recent tribunal decisions are reviewed by Clare Wilson and Edward Reed (Macfarlanes).
Back to basics: Closure notices and the appeals process
Liam McKay
Adam Craggs
Adam Craggs and Liam McKay (RPC) provide a refresher guide.
McCann Media Ltd v HMRC
Taxpayer’s appeal against FTT IR35 appeal unsuccessful.
Other cases that caught our eye: 5 April 2024
Application to strike out MDR claim rejected: HMRC has had a high level of success in appeals involving multiple dwelling and mixed used SDLT reliefs. In Newsand Ltd v HMRC [2024] UKFTT 221 (TC) (13 March 2024), HMRC sought to build on those...
Other cases that caught our eye: 9 February 2024
Estoppel in tax disputes: In A Cattrell v HMRC [2024] UKFTT 67 (TC) (16 January 2024), the FTT dismissed the taxpayer's appeal against the validity of HMRC's closure notice in respect of an enquiry into the taxpayer's self-assessment return (which...
Private client review for January 2024
Edward Reed
Angus Richardson
PPR relief, transfer of assets abroad, information notices and the taxation of f
inder’s fees are among the topics in this month’s review by Edward Reed and
Angus Richardson (Macfarlanes).
HMRC v Dolphin Drilling Ltd
Court of Appeal rules that ‘hire cap’ under the oil contractor regime applied to restrict CT deduction.
JTIAC reaches the Upper Tribunal: onward, through the Slough of Despond, but for which purpose?
Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) is disappointed by a recent Upper Tribunal decision on the unallowable purpose rule.
Illuminate Skin Clinics Ltd v HMRC
Meaning of medical care for purposes of VAT exemption.
GE Financial Investments v HMRC
Residence and the UK/USA double tax treaty.
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18
EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
Professional bodies warn against UTT expansion
Close company reporting: ‘benefits lost in a sea of data’
HMRC clarify CIS treatment of pure financing arrangements
HMRC guidance gives comfort on management rollovers
Further compensation payments exemption
CASES
Read all
Lifeplus Europe Ltd v HMRC
MyPay Ltd v HMRC
WWM (Harrogate) LLP v HMRC
Other cases that caught our eye: 12 June 2026
Bagshaw Ltd v Revenue Scotland
IN BRIEF
Read all
Information notices
Management rollovers and share-for-share exchange relief
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
MOST READ
Read all
HMRC clarify CIS financing positions
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime
Consultation tracker
IHT replacement property relief restrictions