Case reports

Tax | Dental practice wins tax ruling over £980k trust status

The court has ruled against HMRC and found that £980,000 worth of loans made to a director from a remuneration trust were not connected to employment and not subject to tax or National Insurance contributions (NIC)

13 Sep 2021

Tax | Judicial review rejected in £1.8m loan charge repayment case

The High Court has dismissed to grant a judicial review of a decision by HMRC to refuse to give a taxpayer assurance that he would not be taxed if he ‘rescinded’ repayments of loans to an Employee Benefit Trust (EBT)

2 Sep 2021

Tax | Why multiple dwellings relief is a hard hurdle to leap

Zigurds Kronbergs, senior tax writer at Croner-i, looks at recent Tribunal decisions dismissing claims for multiple-dwellings relief from stamp duty land tax and considers ways to use the tax rules to gain advantage

2 Sep 2021

Tax | VAT updates: September 2021

In this month’s round-up of VAT cases, Graham Elliott examines the rulings on exempt services in Target Group, VAT group backdated exemption in Dollar Financial and judicial review at issue in KSM Henryk Zeman

1 Sep 2021

Tax | Court rules for £2.5m corporate tax deductions

The Upper Tribunal (UT) has overturned the First-Tier Tribunal’s (FTT) decision by ruling that corporation tax deductions of £2.5m were eligible for fees relating to advice on the disposal of assets

31 Aug 2021

Business tax

Tax | Court rules that £2.2m car allowances subject to NIC

In a test case for the treatment of car allowances, the First Tier Tribunal has dismissed an appeal by Laing O’Rourke for National Insurance contributions (NIC) relief worth £2.2m

26 Aug 2021

Tax | PPI claims handler loses bid for VAT exemption

The Upper Tribunal has upheld the First Tier Tribunal’s (FTT) decision that the services provided by the Claims Advisory Group Ltd for mis-sold PPI claims were not exempt and were subject to VAT

19 Aug 2021

Tax | Court dismissed £141k multiple dwellings relief claim

The Court dismissed the appellant’s claim for multiple dwellings relief (MDR) leaving the home owner with a £141,750 bill for stamp duty land tax (SDLT)

17 Aug 2021

Property tax

Tax | Contractor left with £1.7m tax bill

A developer linked to several stalled construction sites in Liverpool and under investigation by the Serious Fraud Office has been hit with a tax bill of more than £1.7m

12 Aug 2021

Tax | Bunny Hall loses tax case over £500k land dispute

The First Tier Tribunal has dismissed an appeal against HMRC over the amount of income tax on trade profits and capital gains tax paid on plots of land sold on the estate of a listed building

11 Aug 2021

Property tax

Tax | Court of Appeal rules for Ingenious over trading issue

In the long-running Ingenious court case over the use of tax avoidance schemes, the Court of Appeal has ruled against HMRC over two of key issues at stake, including trading with a view to profit

9 Aug 2021

Tax | Court ruled that taxpayer was estopped in £701k tax case

The Supreme Court overturned the Court of Appeal’s decision that a taxpayer was not estopped from denying that a valid inquiry had been opened into his tax return which declared he owed HMRC £701,990.96, even though the inquiry was sent to the wrong address

4 Aug 2021

HMRC

Tax | VAT updates: August 2021

In this month’s round-up of VAT cases, Graham Elliott examines the major VAT rulings including zero rating on residential new build in CMJ to separate supply issues in Black Cab Services case

2 Aug 2021

Tax | FIL ruling allows statutory interest claim

In the long running case on Franked Investment Income (FIL) Group, the Supreme Court has ruled that double tax relief provisions should be ignored in the settlement process.

28 Jul 2021

Tax | Billionaires lose £4m stamp duty land tax case

The billionaire brothers, Christian and Nicholas Candy have lost their stamp duty land tax (SDLT) battle against HMRC at the Upper Tribunal and have been ordered to pay almost £4m tax on their £68m property purchase

27 Jul 2021

Property tax