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INCOME-TAX
Top ten cases of 2023
Each week,
Tax Journal
reports notable judgments on tax issues that have been handed down by the courts and tribunals. This week, we also look back over 2023 and highlight some cases of interest to a wide range of advisers.
Resetting the clock and the six-year itch: non-domiciliaries resuming UK tax residence
Claire Weeks
Clare Maurice
Claire Weeks and Clare Maurice (Maurice Turnor Gardner) explain why
returning to the UK after a period of non-tax residence is not for the faint
hearted.
Atholl House Productions Ltd v HMRC
Taxpayer wins finely balanced IR35 case remitted from Court of Appeal.
Ask an expert: A case study on de-enveloping
Marc Selby
If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
Transfer pricing and intangibles: are all the issues priced in?
Alex Rigby
James Anderson
James Anderson and Alex Rigby (Skadden) examine HMRC’s package of
proposed transfer pricing reforms, and consider how they might assist with
existing uncertainty and double taxation disputes.
Blurred lines: occupation, profession or vocation?
Liesl Fichardt
Emily Au
Identifying an occupation is a cornerstone of the sale of occupational income rules. As those rules are increasingly invoked by HMRC, Liesl Fichardt and Emily Au (Quinn Emanuel) examine the guiding principles to identify an occupation, profession and vocation, and highlight the areas of obscurity.
How to handle venture capital tax reliefs
Mark Ward
Mark Ward (BDO) explains the qualifying conditions, benefits for investors
and practical points when claiming relief.
Legislation day highlights
Rhiannon Kinghall Were
Rhiannon Kinghall Were (Macfarlanes) examines the draft legislation and
other policy measures published this week.
Five proposed structural changes to the UK tax system
Sarah Gabbai
Sarah Gabbai (McDermott Will & Emery) proposes five reforms that aim to
increase revenues and simplify the UK tax system.
Taxation of home working equipment during Covid-19
Sarah Hewson
Sarah Hewson (EY) explains the extent of the tax exemptions on home working equipment.
Go to page
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8
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 5 September 2025
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
Submitting RIF notifications to HMRC
HMRC guidelines on declarations of accuracy and completeness
EV charging added to advisory fuel rates
CASES
Read all
Lexgreen Services Ltd v HMRC
Elphysic Ltd and others v HMRC
W Tinkler v HMRC
Clear Pay Payroll Ltd v HMRC
Other cases that caught our eye: 5 September 2025
IN BRIEF
Read all
Closing the tax gap: HMRC’s approach to ‘legal interpretation disputes’
CenTax recommends changes to protect family farms
Soft Drinks Industry Levy credit repayments
Self’s assessment: Time for a wealth tax?
Highlights from HMRC’s 2024/25 annual report
MOST READ
Read all
First failure to prevent the facilitation of tax evasion case
T Masters v HMRC
Government mulls reforms to property taxes
Government mulls reforms to property taxes
United Carpets (Franchisor) Ltd v HMRC