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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.
HMRC v T Suterwalla and another
Paddock did not form part of grounds of dwelling for SDLT purposes.
Jelly Vine Productions Ltd v HMRC
Taxpayer’s attempt to avoid full IR35 hearing on previously untested procedural grounds is rejected.
S Sangha v HMRC
FTT varies information notice.
Other cases that caught our eye: 12 July 2024
Interest calculation on restitutionary payment: Test claimants in the franked investment income group litigation v HMRC [2024] EWHC 1671 (Ch) (18 June 2024) is another episode in the saga of the compatibility of the UKs regime for the taxation...
HMRC v Altrad Services Ltd and another
CA overturns UT decision in ‘magic’ capital allowances avoidance scheme.
UK Care No. 1 Ltd v HMRC
Part of loan relationship loss disallowed as referable to period of non-UK tax residence.
J Wardle v HMRC
Entrepreneurs’ relief claim allowed.
Other cases that caught our eye: 5 July 2024
Amortisation of goodwill: AlthoughArmour Veterinary Group Ltd v HMRC [2024] UKFTT 539 (TC) (13 June) is a case about corporation tax relief for the amortisation of goodwill it will be of more interest to partnership practitioners. This is...
P Cox and another v HMRC
Penalties for incorrect BADR claim upheld.
CATS North Sea Ltd v HMRC
Transfer of trade and capital allowances provisions in context of ring fence trade.
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378
EDITOR'S PICK
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Robert Waterson
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Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
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2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
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Lynnette Bober
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Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
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Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
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Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
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Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
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Tamar Ruiz
NEWS
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Tax Journal authors for November 2024
HMRC manual changes: 6 December 2024
Exchequer Secretary committed to MTD timetable following ‘robust’ conversations with HMRC
MTD: catching up with digital records
No new side hustle tax, HMRC confirm
CASES
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Stage One Creative Services Ltd v HMRC
R Grint v HMRC
L v HMRC
Other cases that caught our eye: 6 December 2024
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
IN BRIEF
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A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
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The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
Stage One Creative Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others