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INCOME-TAX


The trials and tribulations of interest withholding tax starpremium
Card image Rebecca Rose Bezhan Salehy Elvira Colomer Fatjo
Bezhan Salehy, Rebecca Rose and Elvira Colomer Fatjo (Macfarlanes) take a practical look at UK interest withholding tax, highlighting common compliance pitfalls, HMRC’s approach and emerging complexities.
2 July 2025
H Osmond and another v HMRC premium
Taxpayers did not have a main purpose of obtaining an income tax advantage
25 June 2025
S Smart v HMRC premium
Taxpayer liable to income tax on sums payable by overseas entities
25 June 2025
A Moran v HMRC premium
TOAA applied on rent-free property settled in an offshore trust
28 May 2025
N Powell v HMRC premium
Novation of director’s loan account 
21 May 2025
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others premium
Payments to an EBT to avoid income tax and NICs did not have a ‘prohibited purpose’
9 April 2025
V Louwman v HMRC premium
Deemed income of settlor of offshore trusts outside the protected settlements regime
19 March 2025
JTC Employer Solutions Trustee Ltd and others v W Garnett and others premium
High Court permits rescission of sub-trust appointments saving IHT for EBTs caught by income tax avoidance rules.
8 January 2025
The Scottish Budget 2025/26: steady as she goes, but with some stings in the tail premium
Card image Alan Barr
Card image Isobel d'Inverno
Isobel d’Inverno and Alan Barr (Brodies) review the Scottish Budget, including the new Scotland’s tax strategy publication which contains a wide range of substantive possibilities for change.
11 December 2024
R Grint v HMRC premium
Sale of occupation income tax charge upheld.
4 December 2024
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B D’Angelin v HMRC
9 July 2025
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