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Other cases that caught our eye: 25 April 2025
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...
Disputes over LPP with third parties and HMRC: lessons from Castlet Holdings
Tristan Thornton
Joseph Howard
A recent FTT decision has exposed the inadequacies in how the rules deal with third party notices, write Joseph Howard and Tristan Thornton (Chancery Court Tax Chambers).
HMRC v BlueCrest Capital Management (UK) LLP
Court of Appeal remits salaried members case to FTT.
GCH Corporation: did HMRC forget to bring their gun to the sword fight?
David Whiscombe
HMRC may have overlooked their own statement of practice which says that
such a transfer is in general a disposal, writes David Whiscombe.
Tax and the City review for November 2024
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) examine the impact of the Autumn Budget and some recent tribunal decisions on the financial sector.
Muller UK and Ireland Group LLP and others v HMRC
Intangible assets related party rules in context of LLP profits calculation.
Salaried LLP members: where are we now?
Jitendra Patel
LLPs would be well advised to consider the status of their members in light of recent developments, writes Jitendra Patel (BDO).
The Boston Consulting Group UK LLP and others v HMRC
Disposals of LLP interests were taxable as miscellaneous income.
Salaried members rules: the position for LLPs after BlueCrest
Ian Zeider
Emily Clark
Emily Clark and Ian Zeider (Travers Smith) revisit the Upper Tribunal’s salaried members judgment in
BlueCrest
, focusing on what it means for LLPs. Is there now more scope to claim ‘significant influence’, but perhaps less certainty of being on the right side of the line?
Tax and the City review for April 2023
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) provide this month’s
round-up that includes Spring Finance Bill measures affecting financial
services.
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