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Upper Tribunal
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Upper Tribunal
UPPER-TRIBUNAL
Complex statutory construction: the Court of Appeal’s approach in Tower One
Cristy Ajediti
Helen Coward
Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.
Saunders: new uncertainty for contractual employee incentive arrangements
Peter North
Rob Sharpe
Rob Sharpe and Peter North (Cleary Gottlieb) examine a recent Upper Tribunal
ruling on the taxation of stock appreciation rights – a decision that introduces
fresh uncertainty for arrangements falling outside ITEPA 2003 Part 7.
Scatola: 20 years to raise s 75A discovery assessments
Sinisa Butina
Angela Savin
Angela Savin and Sinisa Butina (KPMG) examine the basis of the Upper
Tribunal’s reasoning in
Scatola
and the broader ramifications for taxpayers
seeking certainty and finality to their SDLT affairs.
The VAT review for July 2025
Gary Barnett
Jo Crookshank
This month’s review by Jo Crookshank and Gary Barnett (Simmons &
Simmons) covers recent decisions on the single/multiple supply rule and the
VAT finance intermediation exemption, as well as HMRC’s change of policy on
pension scheme costs.
St Patrick’s International College Ltd and others v HMRC
CA allows taxpayer’s appeal on VAT exemption and private higher education providers
HMRC v Align Technology Switzerland GmbH and another
What does the term ‘dental prostheses’ mean?
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
CA upholds conforming interpretation allowing payment of exit taxes by instalments
Other cases that caught our eye: 26 June 2026
VAT on karaoke venue: A reduced rate of VAT was introduced during the pandemic for the right of admission to certain shows, museums, etc. The question in Lucky Voice Group Ltd v HMRC [2026] UKFTT 903 (TC) (16 June) was whether this reduction also...
Barclays Bank plc v HMRC
UT remits loan relationship dispute
HMRC v GCH Corporation Ltd and others
UT confirms broad meaning of ‘business’
Go to page
of
8
EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
Read all
Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
Read all
The VAT treatment of prize draws
The new duty to correct tax return errors
Loan charge settlement scheme: regulations and guidance published
Requirements for forthcoming pensions IHT changes
One minute with... Tim Gummer