INCOME-TAX

Burden of proof and civil penalties: The Court of Appeal in HMRC v Sintra Global Inc and another [2025] EWCA Civ 1661 (18 December 2025) decided in favour of HMRC, holding that the UT had made various errors of law, in particular, by...

Payments to employees under tax avoidance scheme were taxable earnings despite purported repayment obligation

Taxpayers did not have a main purpose of obtaining an income tax advantage

Taxpayer liable to income tax on sums payable by overseas entities

TOAA applied on rent-free property settled in an offshore trust

Novation of director’s loan account 

Payments to an EBT to avoid income tax and NICs did not have a ‘prohibited purpose’

Deemed income of settlor of offshore trusts outside the protected settlements regime

High Court permits rescission of sub-trust appointments saving IHT for EBTs caught by income tax avoidance rules.

Isobel d’Inverno and Alan Barr (Brodies) review the Scottish Budget, including the new Scotland’s tax strategy publication which contains a wide range of substantive possibilities for change.