UPPER-TRIBUNAL

Adam Craggs

Liam McKay

The Court of Appeal restores a strict approach to late appeals, leaving taxpayers facing the familiar Martland hurdle once again, write Adam Craggs and Liam McKay (RPC).

Helen Coward

Cristy Ajediti

Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven 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.

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.

Jo Crookshank

Gary Barnett

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.

Upper Tribunal upholds travel expenses relief for mandatory cabin crew hotel stays

Remote gaming duty exclusion can apply to free spins won from wholly free games

UT refuses permission in HMRC debarment case: S Matin v HMRC [2026] UKUT 343 (TCC) (3 September) is a useful summary of the approach a tribunal will take to an application to debar HMRC from participating in proceedings. The taxpayer was...

Capital repayment by a UK limited company not excluded from Transactions in Securities regime

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

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