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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
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
1 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
2 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
3 /7
Estoppel and abuse of process in VAT
Claire Logan
4 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
5 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
6 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
7 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
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
NEWS
Read all
UK closes the door on foreign branch loss relief
VAT capital goods scheme changes
New guidance on UK-India social security agreement
Mandatory registration brought into force, eventually
HMRC annual report: compliance yield tops £50bn
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
M Lambourne and another v HMRC
HMRC v Align Technology Switzerland GmbH and another
Other cases that caught our eye: 17 July 2026
HMRC v BlueCrest Capital Management (UK) LLP
IN BRIEF
Read all
Directors’ liability: tax schemes
BlueCrest: the impact for asset managers
When Ramsay does not rescue HMRC
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
MOST READ
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Consultation tracker
When Ramsay does not rescue HMRC
Tax and the City for July 2026
BlueCrest: the impact for asset managers
HMRC v BlueCrest Capital Management (UK) LLP