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Other cases that caught our eye: 25 April 2025
SDLT multiple dwellings relief: H Gabra and another v HMRC [2025] UKFTT 399 (TC) (4 April) is one of two cases reported this week on multiple dwellings relief (MDR) – between them they form a good case study on the scope of the relief. In...
Disputes over LPP with third parties and HMRC: lessons from Castlet Holdings
Joseph Howard
Tristan Thornton
A recent FTT decision has exposed the inadequacies in how the rules deal with third party notices, write Joseph Howard and Tristan Thornton (Chancery Court Tax Chambers).
HMRC v BlueCrest Capital Management (UK) LLP
Court of Appeal remits salaried members case to FTT.
GCH Corporation: did HMRC forget to bring their gun to the sword fight?
David Whiscombe
HMRC may have overlooked their own statement of practice which says that
such a transfer is in general a disposal, writes David Whiscombe.
Tax and the City review for November 2024
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) examine the impact of the Autumn Budget and some recent tribunal decisions on the financial sector.
Muller UK and Ireland Group LLP and others v HMRC
Intangible assets related party rules in context of LLP profits calculation.
Salaried LLP members: where are we now?
Jitendra Patel
LLPs would be well advised to consider the status of their members in light of recent developments, writes Jitendra Patel (BDO).
The Boston Consulting Group UK LLP and others v HMRC
Disposals of LLP interests were taxable as miscellaneous income.
Salaried members rules: the position for LLPs after BlueCrest
Emily Clark
Ian Zeider
Emily Clark and Ian Zeider (Travers Smith) revisit the Upper Tribunal’s salaried members judgment in
BlueCrest
, focusing on what it means for LLPs. Is there now more scope to claim ‘significant influence’, but perhaps less certainty of being on the right side of the line?
Tax and the City review for April 2023
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) provide this month’s
round-up that includes Spring Finance Bill measures affecting financial
services.
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
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
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
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New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
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Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
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TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime