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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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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
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Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
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Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
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HMRC manual changes: 5 September 2025
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
Submitting RIF notifications to HMRC
HMRC guidelines on declarations of accuracy and completeness
EV charging added to advisory fuel rates
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Lexgreen Services Ltd v HMRC
Elphysic Ltd and others v HMRC
W Tinkler v HMRC
Clear Pay Payroll Ltd v HMRC
Other cases that caught our eye: 5 September 2025
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Closing the tax gap: HMRC’s approach to ‘legal interpretation disputes’
CenTax recommends changes to protect family farms
Soft Drinks Industry Levy credit repayments
Self’s assessment: Time for a wealth tax?
Highlights from HMRC’s 2024/25 annual report
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First failure to prevent the facilitation of tax evasion case
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Government mulls reforms to property taxes
Government mulls reforms to property taxes
United Carpets (Franchisor) Ltd v HMRC