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CASES

Each week we report the tax cases that matter. Tax Journal subscribers have unrestricted access to the full archive, covering hundreds of cases.

Mobile phone plan bundles.
Court of Appeal rules that automated notices are valid: In PMarano v HMRC [2024] EWCA Civ 876 (26 July), the CA dismissed the taxpayers appeal that the UT erred in holding that FA 2020 s 103 rendered it unnecessary for HMRC to prove the...
Supreme Court finds advisers’ fees were capital in nature.

CA holds that stapled entity not entitled to double tax relief.

UT overturns FTT finding of deliberate behaviour as error of law.
Carried interest base cost shift: In NMillican v HMRC [2024] UKFTT 618 (TC) (5 July), the FTT upheld the taxpayers appeal that his disposal of an interest in a company did not fall within the special regime in the TCGA 1992 which applies...
CJEU confirms that supplies between VAT groups are outside the scope of VAT.
HICBC assessment was ‘protected’.
FTT dismisses taxpayer’s public law arguments against CIS determinations.
Collagen drink not food for VAT purposes: There have seen many cases over the years about the boundaries between cakes and biscuits for VAT purposes but the dispute in Bottled Science Ltd v HMRC [2024] UKFTT 592 (TC) (4 July) was over a more...
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