FTT

Burden of proof and civil penalties: The Court of Appeal in HMRC v Sintra Global Inc and another [2025] EWCA Civ 1661 (18 December 2025) decided in favour of HMRC, holding that the UT had made various errors of law, in particular, by...

Country estate was a mixed-use property

FTT grants HMRC’s costs application

No deduction allowable for provisions in respect of an unfunded unapproved retirement benefit scheme, Court of Appeal rules

‘Stock appreciation rights’ were taxable earnings

No recovery of import VAT by non-owners

Purchase of own shares benefited company’s trade 

Application for reinstatement denied

Employee loan scheme appeal failed: P Brown v HMRC [2025] UKFTT 1226 (TC) (10 October) is a case about an employee loan scheme. The FTT struck out the taxpayer’s appeal on the basis that, following Rangers [2017] UKSC 45, the planning that had been...

Closure notice charging fee to corporation tax as a chargeable gain