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Upper Tribunal
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Upper Tribunal
UPPER-TRIBUNAL
HMRC v The taxpayer
UT sets aside FTT’s direction that preliminary proceedings in the taxpayer’s appeal be heard in private.
View from the Tax Bar in 2023
Laura Poots
Laura Poots (Pump Court Tax Chambers) shares some tips for minimising last minute procedural issues and also reports some positive developments in diversity at the Bar.
Private client Christmas case round-up
Catrin Harrison
Dominic Lawrance
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) give a festive appraisal of the key case decisions in 2023 affecting private clients.
In conversation with... Rt Hon Lady Justice Falk
Anthony Inglese
Dame Sarah Falk talks to Anthony Inglese CB about her progression from life as a tax practitioner to becoming a senior member of the judiciary.
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.
Go to page
of
9
EDITOR'S PICK
The Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
Bolt: Supreme Court refuses permission to appeal
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
HMRC name 196 deliberate tax defaulters
Victoria Oil & Gas plc v HMRC
Loans to participators: s 455