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Upper Tribunal
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Upper Tribunal
UPPER-TRIBUNAL
Capital allowances: a question of design?
Paul Farey
Paul Farey (AECOM) considers the impact of the Upper Tribunal’s ruling in
the
Gunfleet Sands
case.
Certainty vs deterrence: the Supreme Court’s approach to anti-avoidance legislation in Fisher
Ben Elliott
The Supreme Court has effectively left it open to future courts to counteract artificial avoidance, writes Ben Elliott (Pump Court Tax Chambers).
Gunfleet Sands Ltd v HMRC
Capital allowances disallowed for windfarm studies expenditure.
Conduct of proceedings in the Upper Tribunal: new guidance
Kelly Stricklin-Coutinho
New guidance has been issued on the conduct of proceedings in the Upper Tribunal. Kelly Stricklin-Coutinho (39 Essex Chambers) examines what’s changed.
Changes to applying for permission to appeal
Sophie Rhind
Sophie Rhind (Macfarlanes) reports on the game changing amendment to rule 24 of the Upper Tribunal rules.
Is payroll closely connected to welfare work for VAT purposes?
Victor Cramer
Victor Cramer (Stewarts) writes about the potential wider impact of the
Cheshire Centre for Independent Living
decision on payroll services in the care
sector, and questions whether the decision is correct.
Civil or criminal proceedings for serious fraud?
David Sleight
David Sleight (Kingsley Napley) examines a recent Upper Tribunal decision which is important for both tax and criminal litigators alike.
Sippchoice: the meaning of ‘contributions paid’
Matthew Harrison
Matthew Harrison (Withers) examines the Upper Tribunal decision concerning the registered pension scheme regime.
How to handle tax appeals
Constantine Christofi
Adam Craggs
A 20 questions guide, by Adam Craggs and Constantine Christofi
(RPC).
News Corp: VAT treatment of digital newspapers
Karen Killington
The Upper Tribunal has found that digital newspapers could be zero rated. Karen Killington (KPMG) examines the tribunal’s reasoning and discusses its implications.
Go to page
of
5
EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 6 February 2026
Finance Bill measures risk uncertainty, complexity and unintended effects, CIOT warns
Finance Bill round-up
Net settlement and annual reporting requirements
Companies now required to maintain own register of members
CASES
Read all
FS Commercial Ltd v HMRC
P Kearney v HMRC
Mark Glenn Ltd v HMRC
J Hall v HMRC
Other cases that caught our eye: 6 February 2026
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
COP 9 and serious tax fraud: HMRC’s tougher approach
One minute with... Hayley Ives
Consultation tracker
Nimbus: The Disability Consultancy Service Ltd v HMRC