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Private client review for May 2024
Edward Reed
Klara Kronbergs
Edward Reed and Klara Kronbergs (Macfarlanes) review recent cases
concerning entrepreneurs’ relief, PPR and SDLT.
Other cases that caught our eye: 10 May 2024
Freedom of information and legal professional privilege (LPP): Anybody considering making a FOI request in relation to tax matters will find much of interest in the tribunal’s approach to this issue in A Davis v Information Commissioner [2024] UKFTT...
Other cases that caught our eye: 26 April 2024
Bonus arrangements were fully taxable: Lynx Forecourt Ltd v HMRC [2024] UKFTT 278 (TC) (27 March 2024) is an appeal that relates to bonus arrangements put in place as far back as 2003. They were designed to exploit the rules which existed at the...
Private client review for April 2024
Edward Reed
Sam Epstein
Recent decisions on mixed use SDLT, taxpayer behaviour and the meaning of
‘service’ under the remittance basis rules are reviewed by Edward Reed and
Sam Epstein (Macfarlanes).
J Harjono and another v HMRC
Mixed-use SDLT appeal failed
VAT on residential property development: a case study
Michael Ridsdale
Gemma Williams
Michael Ridsdale and Gemma Williams (Wedlake Bell) illustrate how to
ensure certainty of tax treatment on the structuring of a residential property
development.
HMRC v D Ridgway
Upper Tribunal rules against mixed use determination.
M Brown and another v HMRC
Court of Appeal rejects SDLT scheme.
Other cases that caught our eye: 15 February 2024
Application to be joined as a party: The APP Accounting Group Ltd v Uberdev Ltd and another [2024] UKFTT 100 (TC) (25 January) is a case management decision in which the FTT allowed an application for a third party (TAAG) to be added to an appeal as...
Other cases that caught our eye: 26 January 2024
BADR and trusts:Trustees of the Peter Buckley Settlement v HMRC [2024] UKFTT 29 (TC) (4 January 2024) emphasises an important point about business asset disposal relief and trusts. A trust can obtain relief on a disposal of a qualifying asset (in...
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
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HMRC manual changes: 9 January 2026
Agreement reached on Pillar Two ‘side-by-side’ package
Late change lifts BPR/APR cap
New guidelines on imported hybrid mismatch rules
VAT treatment of supplies of temporary medical staff
CASES
Read all
HMRC v Hotel La Tour Ltd
County Insurance Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
R Sehgal v HMRC
Other cases that caught our eye: 9 January 2026
IN BRIEF
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TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
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Finance Bill 2026 published
Tax in 2025: the good, the bad and the ugly
A year at the Tax Bar in 2025
End of year musings on corporate tax
R&D tax in 2025: the calm after the storm?