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RPC Tax Take

For tax professionals on the move

Tribunal allows taxpayer's appeal and confirms he was carrying on a trade on a commercial basis

Posted on February 05, 2016 by Nicole Kostic
Nicole Kostic
Nicole is an Associate at RPC and specialises in contentious tax work. She advis
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In Akhtar Ali v HMRC [2016] UKFTT 8 (TC), the First-tier Tribunal (FTT), in allowing the taxpayer's appeal, has provided some helpful guidance on the factors to be taken into consideration when deciding whether activities comprise a trade which is commercial, for the purposes of section 66, Income T... read more

Court of Appeal confirms validity of third party information notices

Posted on January 29, 2016 by Adam Craggs
Adam Craggs
Adam heads our market-leading Tax Disputes team and is an accredited mediator. H
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In Derrin Brothers Properties Limited & Others v HMRC [2016] EWCA Civ 15, the Court of Appeal  has dismissed the Appellants' appeal against the High Court's refusal to quash third party information notices issued by HMRC pursuant to paragraph 2, Schedule 36, Finance Act 2008 (the Notices).   B... read more

HMRC fails to satisfy the Tribunal that residential property purchased for a pension fund was "taxable property"

Posted on January 20, 2016 by Nicholas Fernyhough
Nicholas Fernyhough
Nick Fernyhough is a Senior Associate in RPC's tax dispute resolution team, with
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In J & A Young (Leicester) Limited and Others v HMRC [2015] UKFTT 0638 (TC) TC 04771, the First-tier Tribunal (FTT), has allowed the taxpayers' appeals and held that certain residential property acquired by a self-administered occupational pension scheme was not "taxable property", for the purpo... read more

Supreme Court confirms that when making a confiscation order and assessing the amount of benefit obtained by an offender any VAT accounted to HMRC should be ignored

Posted on January 14, 2016 by Adam Craggs
Adam Craggs
Adam heads our market-leading Tax Disputes team and is an accredited mediator. H
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In R v Harvey [2015] UKSC 73, the Supreme Court allowed the appeal of Mr Jack Harvey (the Appellant) against the decision of the Court of Appeal (Criminal Division) and confirmed that when making a confiscation order, and assessing the amount of benefit obtained by an offender within the meaning of ... read more

Tribunal allows company's appeal and confirms that the four-year time limit does not apply to corporation tax self-assessment returns

Posted on January 08, 2016 by Robert Waterson
Robert Waterson
Robert is a senior associate at RPC with 8 years’ experience in direct tax and V
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In Bloomsbury Verlag GmbH v HMRC [2015] UKFTT 660 (TC),the First-tier Tribunal (Tax and Chancery) (FTT) has held that the four-year time limit does not apply to corporation tax self-assessment returns and that trading losses can be carried forward even though they were not  included in a return.  ... read more

UK source of interest

Posted on December 30, 2015 by Adam Craggs
Adam Craggs
Adam heads our market-leading Tax Disputes team and is an accredited mediator. H
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In Ardmore Construction and Andrew Perrin v HMRC [2015] UKUT 633 (dual appeal), the Upper Tribunal (UT) dismissed the taxpayers appeals and confirmed that they had received UK source dividends on which UK income tax was deductible at source.   Background   Ardmore Construction Ltd (Ardmore) and ... read more

Appealing to the Upper Tribunal

Civil Tax Appeals

Funding tax litigation

Confiscation orders

Restraint proceedings

The role of the forensic accountant

Interviews under caution

Arrest and what happens next

Dawn raids’ and risk management

HMRC’s Criminal Powers

About this blog

Albert Einstein once remarked, on trying to complete his tax return: "This is too difficult for a mathematician. It takes a philosopher!". As tax practitioners are only too well aware, tax legislation continues to increase in length and complexity with the passing of each Finance Act. There is also a steady stream of new case law. Our hope is that, against this background, RPC Tax Take will be a useful source of current information and comment to busy practitioners. It features regular postings on the latest news and developments in UK tax law, together with a number of practical Practice Notes written by specialist lawyers at RPC.

We welcome comments and feedback – please get in touch!

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Tag Cloud

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