APNS

SDLT multiple dwellings relief: H Gabra and another v HMRC [2025] UKFTT 399 (TC) (4 April) is one of two cases reported this week on multiple dwellings relief (MDR) – between them they form a good case study on the scope of the relief. In...

Employee loan arrangements: FS Capital Ltd and others v A Adams and others [2025] EWCA Civ 53 (28 January) is yet another twist in the long saga of employee loan arrangements and their resolution. It is not a tax case as such but will be of interest...

No hardship with VAT assessment: A taxpayer wishing to appeal to a tribunal against a VAT assessment must either pay the disputed tax up front or apply to HMRC or the tribunal for permission not to pay the assessment on grounds of hardship. SC...

Upper Tribunal dismisses challenges to accelerated payment notices.

The unsatisfactory truth. 

Barrister Michael Thomas (Pump Court Tax Chambers) believes there is a disturbing trend in our tax jurisprudence: an increasing number of important decisions made by HMRC are only capable of being challenged on a judicial review basis.

Current taxpayer safeguards for HMRC’s notice powers are neither independent nor accessible, writes Tracey Bowler (Institute for Fiscal Studies).