FTT

UT overturns FTT finding of deliberate behaviour as error of law.

HICBC assessment was ‘protected’.

FTT varies information notice.

Clare Wilson

Edward Reed

A new Finance Act and several recent tribunal decisions are reviewed by Clare Wilson and Edward Reed (Macfarlanes).

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) provide a refresher guide.

Taxpayer’s appeal against FTT IR35 appeal unsuccessful.

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...

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...

Edward Reed

Angus Richardson

PPR relief, transfer of assets abroad, information notices and the taxation of finder’s fees are among the topics in this month’s review by Edward Reed and Angus Richardson (Macfarlanes).

Court of Appeal rules that ‘hire cap’ under the oil contractor regime applied to restrict CT deduction.

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