TRADE

When does preparation become trading? Hannah Manning and Elissavet Grout (Travers Smith) explore why the Upper Tribunal’s Putney Power decision matters for EIS, EMI, SSE and other tax reliefs.

HICBC and taxpayer’s use of AI: In R Huish v HMRC [2026] UKFTT 129 (TC) (16 January), the FTT allowed the taxpayer’s appeal against discovery assessments purportedly charging him to the high income child benefit charge (HICBC) for 2015/16. HMRC made...

Purchase of own shares benefited company’s trade 

Scope of closure notices

Trade losses not recoverable: Losses made in a trade carried on by a sole trader can be set against his or her other income. However, relief is not available where the trade is not carried on a commercial basis with a view to profit. C Macdonald v...

Among the executive orders signed by President Trump is a firm rebuff of the OECD’s two-pillar solution, writes Tanja Velling (Slaughter and May).

Transfer of trade and capital allowances provisions in context of ring fence trade.

Provision for future payments under an unfunded retirement benefit scheme not wholly and exclusively for trade purposes.

Option not acquired for exclusive purpose of a property development trade