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Court of Appeal
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Court of Appeal
COURT-OF-APPEAL
A Beard v HMRC
Court of Appeal finds that distributions debited to company’s share premium account were dividends that were not capital in nature
A Taxpayer v HMRC
Court of Appeal decides moral obligations can be part of ‘exceptional circumstances’ for statutory residence test.
P Marano v HMRC
Court of Appeal considers validity of automated notices and assessments.
HMRC v Altrad Services Ltd and another
CA overturns UT decision in ‘magic’ capital allowances avoidance scheme.
Back to BlackRock: the Court of Appeal restores order
Helen Buchanan
Sarah Bond
The Court of Appeal judgment restores order, write Sarah Bond and
Helen Buchanan (Freshfields Bruckhaus Deringer).
The VAT review for April 2024
Jo Crookshank
Gary Barnett
Pensions funds, Reemtsma claims and supplies by NHS trusts are among the topics in this month’s VAT review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
M Brown and another v HMRC
Court of Appeal rejects SDLT scheme.
Certainty vs deterrence: the Supreme Court’s approach to anti-avoidance legislation in Fisher
Ben Elliott
The Supreme Court has effectively left it open to future courts to counteract artificial avoidance, writes Ben Elliott (Pump Court Tax Chambers).
Characterising supplies for VAT following Mesto Zamberk
Michael Thomas KC
The characterisation test for VAT has received important clarification from the Court of Appeal, writes Michael Thomas KC (Pump Court Tax Chambers).
The role of the Court of Appeal in tax disputes
Hartley Foster
George Gillham
The Ministry of Justice’s claims that the Court of Appeal is being
overwhelmed by vexatious litigants are not well founded in the context of tax,
as Hartley Foster and George Gillham (Fieldfisher) explain.
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3
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 18 July 2025
Chancellor outlines financial services strategy
CIOT reviews transfer pricing proposals
Marriage allowance: backdating claims
Further HMRC update on VAT penalties
CASES
Read all
Abbotsford Property Group Ltd and another v Revenue Scotland
R (oao Thomas Holdings Ltd and others) v HMRC
G Stenhouse and another v HMRC
Other cases that caught our eye: 18 July 2025
B D’Angelin v HMRC
IN BRIEF
Read all
HMRC’s approach to wealthy individuals
There’s only one POEM
Discovery assessments: agents
Standish v Standish
Section 899 compromise shifts international tax landscape
MOST READ
Read all
‘Legislation Day’ date announced
One Big Beautiful Bill Act enacted
G Haworth and others v HMRC
Abbotsford Property Group Ltd and another v Revenue Scotland
One minute with... Charlie Friend