TRADING

Jennifer Plummer (BDO) considers the requirements for this valuable relief and outlines some of the complexities involved where corporate structures are not straightforward.

CA denies capital loss relief on £2.2m loan to trading company

EIS denied as trading purpose unproven: In My Club Web Services Ltd v HMRC [2026] UKFTT 1417 (TC) (9 October), the FTT dismissed the company’s appeal against HMRC’s withdrawal of EIS relief, finding that it had failed to establish that it...

Developer profits were ‘income derived from immovable property’ under DTT so UK retained taxing rights, Upper Tribunal rules

FoI request: In Thomas Elsbury v The Information Commissioner [2025] UKFTT 915 (GRC) (2 August), the FTT (General Regulatory Chamber) allowed an appeal against an Information Commissioner Decision Notice upholding HMRC’s decision to neither...

Rupert Shiers

Suzanne Hill

Rupert Shiers and Suzanne Hill (Hogan Lovells) examine a recent ruling on whether a corporation tax deduction is allowable for significant expenditure in settling a regulatory investigation.

Clare Wilson

Edward Reed

Edward Reed and Clare Wilson (Macfarlanes) review the latest cases on EIS, BPR, reasonable excuse, and the principles of open justice and privacy.

Company did not commence trading before EIS deadline.

Kyle O'Sullivan

The Supreme Court has delivered its judgment in Centrica Overseas Holdings. Kyle O’Sullivan (BCLP) reviews the case and its implications.

Christopher Eames

A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.

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