APPEALS

Adam Craggs and Liam McKay (RPC) review lessons from several important procedural decisions and a successful challenge to HMRC’s approach to subject access requests.

JR challenge to APNs refused: In R (oao Adviser Business Solutions Ltd and others) v HMRC [2025] EWHC 1641 (Admin) (30 June), the HC refused permission to challenge Accelerated Payment Notices (APNs), holding that where HMRC have already formed...

Supreme Court ruling on oil contractor regime

HMRC permission to appeal against case management decisions refused

Closure notices relating to a claim for share loss relief were validly made 

FTT warning over the dangers of using AI

Trade losses not recoverable: Losses made in a trade carried on by a sole trader can be set against his or her other income. However, relief is not available where the trade is not carried on a commercial basis with a view to profit. C Macdonald v...

Discovery assessment invalid

Strike out of appeal after failure to cooperate: J Firth v HMRC [2025] UKFTT 428 (TC) (15 April) is a long decision on whether the FTT should accede to HMRC’s request to strike out an appeal. This was on the basis that the taxpayer had failed...