PENALTIES

Kate Garcia and Thomas Wilkinson (Shoosmiths) review the consultation on the potential redesign or reform of penalties imposed for inaccuracies in tax returns and failures to notify.

Jessica Kemp

Catherine Hill

The January Barclays tech outage shines a light on the sometimes uncompromising interest and penalty regimes facing taxpayers which, in this context, demand flexibility, write Jessica Kemp and Catherine Hill (White & Case).

Determining domicile: In A Weis v HMRC [2025] UKFTT 348 (TC) (21 March), the taxpayer, a Rabbi, had been born in the UK in 1949 in Manchester to a father who had been born in Eastern Europe but had come to the UK in 1938. The father had acquired...

Adequacy of reasons given by FTT: In H Rafferty v HMRC [2025] UKUT 63 (TCC) (19 February), the taxpayer was given limited permission to appeal to the UT against closure notices, assessments and penalties. The decision of the UT in rejecting the...

Employee loan arrangements: FS Capital Ltd and others v A Adams and others [2025] EWCA Civ 53 (28 January) is yet another twist in the long saga of employee loan arrangements and their resolution. It is not a tax case as such but will be of interest...

Daniel Lusted

Daniel Lusted (BDO) examines what’s being proposed.

SDLT MDR was available:T Yeomans v HMRC [2024] UKFTT 955 (TC) (24 October) is another SDLT multiple dwellings relief case but unlike some other cases, where the phrase ‘clutching at straws’ comes to mind, this one was clearly...

Sophie Rhind

Victoria Braid

Mainpay should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).