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Private client review for May 2024
Klara Kronbergs
Edward Reed
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
Sam Epstein
Edward Reed
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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10
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Staggered roll-out for mandatory tax adviser registration
Consultation on proposed UK corporate re-domiciliation regime
Cryptoassets taxation: stablecoins
Administrative change to CIR rules
NIC regs mirror tax changes
CASES
Read all
HMRC v Colchester Institute Corporation
HMRC v Boehringer Ingelheim Ltd
R (oao Rokos) v HMRC
Other cases that caught our eye: 10 April 2026
HMRC v C Brzezicki
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
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J Hosking v HMRC
Exceptional circumstances – but which way?
Countrywide Partners Ltd v HMRC
Muller UK and Ireland Group LLP and others v HMRC
Consultation tracker