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Group relief
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Group relief
GROUP-RELIEF
When company law attacks: group relief traps
Sam Pennington
Matthew Rowbotham
Matthew Rowbotham and Sam Pennington (Lewis Silkin) explore the
company law issues on group relief surrenders and the traps that lie in wait.
Abbotsford Property Group Ltd and another v Revenue Scotland
Scottish FTT upholds Revenue Scotland’s assessments relating to incorrectly claimed LBTT group relief
Lloyds Asset Leasing Ltd v HMRC
FTT denies cross-border group relief claim on main purpose grounds.
Tax grouping (part 1): group relief and tax groupings
Maddy Potthast
Gavin Little
In the first in a series of articles on corporate tax issues, Gavin Little and
Maddy Potthast (Interpath) focus on the conditions for corporation tax loss
relief via group relief.
The Tower One St George Wharf Ltd v HMRC
UT denies SDLT group relief because of tax avoidance main purpose.
Share deals: when is the optimum time to sell?
Laura Frenck
Lorna McCaa
Tax implications for sellers will often influence the optimum time to sell a company. Lorna McCaa and Laura Frenck (Dentons) address the main tax implications for UK corporate sellers and the related timing considerations.
Mainly ignored? The main purpose test for SDLT group relief
Helen Coward
Helen Coward (Charles Russell Speechlys) examines the decision in
The Tower One St George Wharf Ltd
concerning the SDLT group relief
anti-avoidance rule.
VolkerRail: applying retained EU case law in pre-Brexit years
Richard Doran
Davinder Sahota
A decision of the Upper Tribunal illustrates the difficulties of applying CJEU case law for disputes over pre-Brexit breaches of EU law, write Richard Doran and Davinder Sahota (EY).
Back to basics: SDLT and partnerships
Anisha Polson
Paul Beausang
Paul Beausang and Anisha Polson (Eversheds Sutherland) provide a
refresher guide to what must be among the most complex of all the SDLT
rules.
EU freedoms in cross-border transactions
Dominic Stuttaford
Greg Branagan
Two recent decisions have sought to clarify the extent to which the EU freedom of establishment and of the movement of capital were restricted in light of various UK legislative provisions dealing with cross-border transactions and/or operations, as Dominic Stuttaford and Greg Branagan (Norton Rose Fulbright) explain.
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3
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
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
NEWS
Read all
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
Foreign PE exemption becoming mandatory
HMRC v GCH Corporation Ltd and others
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’