LIQUIDATIONS

Paul Townson and Chris Holmes (BDO) examine the recent changes which are making the loans to participators regime more onerous for close companies and advisers.

Jennifer Plummer

Jennifer Plummer (BDO) considers the requirements for this valuable relief and outlines some of the complexities involved where corporate structures are not straightforward.

Liesl Fichardt

Emily Au

HMRC’s preferential ranking brings into sharp focus their requirements to evidence and substantiate their claims in an insolvency, as Liesl Fichardt and Emily Au (Quinn Emanuel) explain.

Liquidation of parent company to preserve SDLT group relief did not have tax avoidance main purpose

Normal expenditure out of income: J Wood v HMRC [2026] UKFTT 589 (TC) (16 April) is the second recent decision, after Hosking [2026] UKFTT 406 (TC) (see Tax Journal, 27 March 2026), on the limits of the IHT exemption for gifts out of income....

Costs awarded because of taxpayer’s unreasonable conduct: In HMRC v Mattu [2025] UKUT 410 (TCC) (16 December 2021), the UT awarded HMRC £5,000 in costs under rule 10(3)(d) of the UT rules (SI 2008/2698), confirming that there is no requirement for a...

Upper Tribunal decides that HMRC lawfully refused late claim under SP 5/01

Director’s loan was not written off or released on liquidation

Ben Lee

In a sector reliant on software for tax solutions, Ben Lee (Andersen) explores the dangers of placing too much faith in ‘tax calculators’.

Post-cessation trade relief/notice of enquiry into return: There are two distinct aspects to A Dennison v HMRC [2024] UKFTT 364 (TC) (2 May 2024). The substantive issue is whether or not the taxpayer was entitled to claim relief under the...

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