Latest by Keziah Mastin

Blog

Follower notice penalties cancelled as failure to take 'corrective action' was reasonable in all the circumstances

Published on 06 July 2022. By Keziah Mastin, Associate

Allowing an appeal by Mr Andreae, the First-tier Tribunal cancelled penalties HMRC had issued for failure to take corrective action following receipt of follower notices. It was held that this failure was reasonable in all the circumstances where Mr Andreae had relied on the advice of a scheme promotor and later sought further advice from an independent advisor.

Read more
Blog

Appeal against discovery assessment allowed as SATR was filed by unauthorised agent

Published on 08 June 2022. By Keziah Mastin, Associate

Allowing an appeal by Mr McCumiskey, the First-tier Tribunal held that HMRC's discovery assessment was invalid on the basis that the purported tax-return had been fraudulently filed and had included an unauthorised and unsubstantiated claim for SEIS relief.

Read more
Blog

Accounting rules prevail following HMRC loss in the Supreme Court

Published on 18 May 2022. By Keziah Mastin, Associate

Dismissing an appeal by HMRC, the Supreme Court in HMRC v NCL Investments Ltd and another [2022] UKSC 9, held that deductions for corporation tax purposes are allowable for grants of employee share options.

Read more
Blog

Taxpayer successfully appeals information notices as information requested not reasonably required

Published on 20 April 2022. By Keziah Mastin, Associate

Allowing an appeal against HMRC's information notices, the First-tier Tribunal in Yerou and another v HMRC [2022] UKFTT 79 (TC), found that the information was not reasonably required.

Read more
Blog

No tax due on transfer of business to connected company

Published on 23 March 2022. By Keziah Mastin, Associate

The First-tier Tribunal in Conran and another v HMRC [2022] UKFTT 39 (TC), concluded that the transfer of a business between connected parties resulted in no capital gains tax liability for the seller, having reduced the stated £8.25m valuation of the business to £1 for tax purposes.

Read more
Blog

No power for HMRC to issue partial closure notice without assessment of tax due

Published on 23 February 2022. By Keziah Mastin, Associate

The Court of Appeal has confirmed that HMRC cannot issue a partial closure notice without assessment of tax due.

Read more