FTT

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.

Gerald Montagu

Gerald Montagu (Gide Loyrette Nouel) is disappointed by a recent Upper Tribunal decision on the unallowable purpose rule.

Meaning of medical care for purposes of VAT exemption.

Residence and the UK/USA double tax treaty.

Disregarding carry-back loss claim in closure notice appeal.

HICBC and discovery assessment powers: There is no sign of the flow of high income child benefit charge (HICBC) cases drying up. HMRC presumably hoped that the retrospective legislation to reverse the decision in Wilkes [2020] UKUT 150 (TCC), where...

Double tax treaty did not confer UK taxing rights to oil royalty payments.

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