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FTT


Statutory residence: transit exemption and exceptional circumstances
Discovery, debt assignment, distribution and penalties: In S Thomas v HMRC [2026] UKFTT 627 (TC) (24 April), the FTT decided that when the company assigned to its controlling shareholder a debt of £2.1m owed to the company by a third party, the...
DTT anti-abuse provision did not deny UK withholding exemption  
EBT was not remuneration
Invalid discovery assessment concerning failed SDLT scheme.
Capital allowances not available for environmental studies expenditure
Profits arose from oil extraction activities
A reusable container is not necessarily a separate supply 
Capital allowances: ring fence trades and intra-group transfers
Host employer rules: no control needed for NIC liability.
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