Tax Take

Perspective - Blog

Tribunal confirms no tax due on disposal of property held on trust for taxpayer's brother

Published on 18 July 2024. By Keziah Mastin, Associate

Signpost pointing in different directions

In Raveendran v HMRC [2024] UKFTT 273 (TC), the First-tier Tribunal allowed the taxpayer's appeal against HMRC's discovery assessment in relation to the disposal of a property because it was held on trust for his brother.

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Perspective - Podcast

Taxing Matters: Spotlight 63: HMRC shines a light on property business arrangements involving hybrid partnerships

16 July 2024

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Simon Howley and Amanda Perrotton from Bell Howley Perrotton LLP. They discuss HMRC's Spotlight 63, which focuses on property business arrangements involving hybrid partnerships, which have recently come to the attention of HMRC.

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Perspective - Blog

Tribunal confirms loans from remuneration trust were disguised remuneration

Published on 11 July 2024. By Liam McKay, Senior Associate

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In allowing HMRC's appeal in part, the Upper Tribunal determined that payments received under a remuneration trust scheme were caught by the anti-avoidance provisions in Part 7A of the Income Tax (Earnings and Pensions) Act 2003.

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Perspective - Blog

Dealing with HMRC information notices

Published on 04 July 2024. By Adam Craggs, Partner and Daniel Williams, Associate

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Considering three common types of HMRC information notices and the extent to which they can be challenged.

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Perspective - Publication

Tax Bites – July 2024

Published on 02 July 2024. By Adam Craggs, Partner

Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

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Perspective - Publication

V@ update – June 2024

Published on 26 June 2024. By Adam Craggs, Partner

Welcome to the June 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world.

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Perspective - Blog

Tribunal awards taxpayer his costs due to HMRC's unreasonable conduct

Published on 20 June 2024. By Jasprit Singh, Senior Associate

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In Aftab Ahmed v HMRC [2024] UKFTT 00236 (TC), the First-tier Tribunal granted the taxpayer's application for costs as HMRC had acted unreasonably in defending the appeal.

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Perspective - Blog

Tribunal allows entrepreneurs' relief appeal

Published on 13 June 2024. By Keziah Mastin, Associate

Signpost pointing in different directions

In Cooke v HMRC [2024] UKFTT 272 (TC), the FTT allowed the taxpayer's appeal against HMRC's refusal of entrepreneurs' relief

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Perspective - Podcast

Exploring tax from an ESG perspective

07 June 2024

In this month's episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Paul Monaghan, Chief Executive and co-founder of the Fair Tax Foundation to discuss the growing interest in tax from an ESG perspective, and the work of the Fair Tax Foundation.

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Perspective - Blog

What happens in an HMRC criminal investigation

Published on 06 June 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

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Perspective - Publication

Tax Bites – June 2024

Published on 05 June 2024. By Adam Craggs, Partner

Signpost pointing in different directions

Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

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Perspective - Blog

Tribunal dismisses HMRC's appeal and confirms transactions did not give rise to a taxable remittance

Published on 30 May 2024. By Liam McKay, Senior Associate

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In dismissing HMRC's appeal, the Upper Tribunal confirmed that transactions entered into by the taxpayers for the sale of shares did not amount to a taxable remittance under section 809L of the Income Tax Act 2007 because no service was provided in the UK.

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Perspective - Blog

Key features of the new non-UK domicile regime

Published on 29 May 2024. By Michelle Sloane, Partner and Jasprit Singh, Senior Associate

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The UK government's unexpected announcement in Spring Budget in March on the taxation of non-domicile individuals has sparked concerns and much comment. It represents a major change to the current system of taxation, which is more than 200 years old.

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Perspective - Publication

V@ update – May 2024

Published on 28 May 2024. By Adam Craggs, Partner

Signpost pointing in different directions

Welcome to the May 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world.

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Perspective - Publication

Customs and excise quarterly update - May 2024

Published on 21 May 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

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Welcome to the May 2024 edition of RPC's Customs and Excise Quarterly Update.

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Perspective - Podcast

The latest on the loan charge scandal with Matt Hall from Armadillo

21 May 2024

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Chartered Tax Adviser, Matt Hall from Armadillo to discuss the latest on what is often referred to as the "loan charge scandal".

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Perspective - Blog

Taxpayers' application for  protective costs order against HMRC refused

Published on 20 May 2024. By Alexis Armitage, Senior Associate

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UT dismisses taxpayer's application for a protective costs order against HMRC.

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Perspective - Blog

Contentious Tax Update

Published on 16 May 2024. By Harry Smith, Senior Associate and Adam Craggs, Partner

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Harry Smith and Adam Craggs examine developments in relation to DOTAS, R&D enquiries, and the Economic Crime and Transparency Act.

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Perspective - Blog

Tribunal allows taxpayer's appeal in R&D case against penalty assessment for careless inaccuracy

Published on 03 May 2024. By Jasprit Singh, Senior Associate

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In H & H Contract Scaffolding Ltd v HMRC [2024] UKFTT 00151 (TC), the First-tier Tribunal (FTT) allowed the taxpayer's appeal against a penalty assessment as the inaccuracy in the tax return was not careless.

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Perspective - Publication

Tax Bites – May 2024

Published on 01 May 2024. By Adam Craggs, Partner

Signpost pointing in different directions

Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

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Perspective - Blog

Contentious tax quarterly: Spring review

Published on 01 May 2024. By Adam Craggs, Partner and Harry Smith, Senior Associate

Signpost pointing in different directions

The last few months have seen a flurry of activity in relation to the DOTAS regime, with HMRC seeking to register arrangements retrospectively and apply substantial penalties for failure to register. Woes continue for those unfortunate enough to have R&D claims under enquiry, and the Economic Crime and Corporate Transparency Act 2023 gives HMRC a significant new tool in relation to suspected criminal activity by bodies corporate and partnerships.

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Perspective - Podcast

Changes to non-domiciliary rules with Philip Simpson KC and Ben Symons

30 April 2024

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team is joined by Philip Simpson KC and Ben Symons from Old Square Tax Chambers, to discuss the Government's Spring Budget and, in particular, the proposed changes that will affect non-UK domiciled individuals.

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Perspective - Blog

Taxpayer's appeal against penalties under the Follower Notice regime allowed

Published on 29 April 2024. By Keziah Mastin, Associate

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In Baker v HMRC [2024] UKFTT 126 (TC), the First-tier Tribunal allowed the taxpayer's appeal and cancelled follower notice penalties that were issued as a result of the taxpayer's alleged failure to take 'corrective action'.

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Perspective - Publication

V@ update – April 2024

Published on 24 April 2024. By Adam Craggs, Partner

Signpost pointing in different directions

Welcome to the April 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.

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Perspective - Blog

Tax Tribunal upholds taxpayer's appeal in respect of remote gaming duty

Published on 22 April 2024. By Liam McKay, Senior Associate

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In allowing the taxpayer's appeal, the First-tier Tribunal determined that cashback payments constituted prizes won for the purposes of section 157 of the Finance Act 2014 and Remote Gaming Duty.

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Perspective - Blog

Costly objection by HMRC

Published on 15 April 2024. By Harry Smith, Senior Associate

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FTT allows costs application where HMRC acted unreasonably in opposing specific disclosure application.

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Perspective - Blog

Upper Tribunal upholds penalty imposed for failing to take 'corrective action' in response to a follower notice

Published on 08 April 2024. By Alexis Armitage, Senior Associate

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Upper Tribunal dismisses taxpayer’s appeal against a penalty issued under the follower notice regime for failing to take corrective action, as the final judicial ruling specified in the follower notice was relevant to the arrangements the taxpayer had implemented.

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Perspective - Publication

Tax Bites – April 2024

Published on 03 April 2024. By Adam Craggs, Partner

Signpost pointing in different directions

Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

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Perspective - Blog

Tribunal allows appeals against discovery assessments

Published on 02 April 2024. By Jasprit Singh, Senior Associate

Signpost pointing in different directions

In Charles Collier and CB Collier Partnership v HMRC [2023] UKFTT 00993 (TC), the First-tier Tax Tribunal (FTT) found that the assessed loss of tax was not brought about deliberately by the taxpayers and had occurred due to carelessness. The 6-year time limit therefore applied to HMRC making assessments and amendments and, under that time limit, HMRC were out of time. The taxpayers' appeals were allowed.

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Perspective - Publication

V@ update - March 2024

Published on 26 March 2024. By Adam Craggs, Partner

Signpost pointing in different directions

Welcome to the March 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.

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Perspective - Blog

Taxpayer's appeal succeeds as HMRC failed to open enquiry in time

Published on 25 March 2024. By Keziah Mastin, Associate

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In Monks v HMRC [2023] UKFTT 853 (TC) the First-tier Tribunal concluded that HMRC had not opened a valid enquiry because the taxpayer didn't receive HMRC's letter until after the relevant time limit had expired.

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Perspective - Blog

Supreme Court provides clarity on Transfer of Assets Abroad legislation

Published on 18 March 2024. By Liam McKay, Senior Associate

Signpost pointing in different directions

In allowing the taxpayers' appeal, the Supreme Court determined that shareholders were not "transferors" for the purposes of the Transfer of Assets Abroad regime in the Income and Corporation Taxes Act 1988.

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Perspective - Blog

Home run! - Tribunal finds that taxpayer who bought and sold three properties in quick succession was not trading

Published on 11 March 2024. By Harry Smith, Senior Associate

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Taxpayer purchasing, renovating and selling properties allowed private residence relief on capital gain and held not to be trading as property developer for tax purposes.

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Perspective - Podcast

International Women's Day special – Inspiring inclusion with Tax Titan Trio

08 March 2024

To celebrate International Women's Day 2024, we have produced a special episode of RPC's Taxing Matters podcast in which we discuss this year's campaign theme #InspireInclusion and what it means to each of our guest speakers.

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Perspective - Publication

Tax Bites - February 2024

Published on 07 March 2024. By Adam Craggs, Partner

Signpost pointing in different directions

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

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Perspective - Blog

A look into HMRC's toolbox during a criminal investigation

Published on 05 March 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

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HMRC has far-reaching powers it can deploy during a criminal investigation into suspected tax fraud, which include applying for and executing search warrants (colloquially referred to as a "dawn raid"), making arrests and the compulsorily obtaining information and documentation through production orders and disclosure notices/orders. A criminal investigation conducted by HMRC is one of the most stressful events a business can experience and failing to properly respond can have serious repercussions, including significant financial and reputational damage or even prison time for individuals.

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Perspective - Publication

V@ update - February 2024

Published on 28 February 2024. By Adam Craggs, Partner

Signpost pointing in different directions

Welcome to the February 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.

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Perspective - Publication

Customs and excise quarterly update - February 2024

Published on 28 February 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

Signpost pointing in different directions

Welcome to the February 2024 edition of RPC's Customs and Excise Quarterly Update.

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Perspective - Blog

Tribunal allows taxpayers' appeals against discovery assessments as company could not distribute goodwill it did not own

Published on 26 February 2024. By Alexis Armitage, Senior Associate

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Tribunal allows taxpayers' appeals against HMRC discovery assessments as company could not distribute goodwill it did not own.

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Perspective - Podcast

A whistlestop tour of the taxation of international sports and rock stars with Patrick Way KC

21 February 2024

In this episode, RPC's Taxing Matters Host and Senior Associate in RPC's Tax Disputes team, Alexis Armitage, will be discussing the taxation of international sports and rock stars with leading silk, Patrick Way KC.

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Perspective - Blog

Tribunal varies Schedule 36 information notice as it sought material not reasonably required by HMRC

Published on 19 February 2024. By Jasprit Singh, Senior Associate

Signpost pointing in different directions

In Parker Hannifin (GB) Ltd v HMRC [2023] UKFTT 00971 (TC), the First-tier Tribunal found that an information notice issued by HMRC, under Schedule 36, Finance Act 2008, was not invalid because it required electronic searches using a list of specified search terms but it did seek information that was legally privileged or not "reasonably required" and the notice was varied accordingly.

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Perspective - Blog

Upper Tribunal remits CGT appeal back to Tribunal for rehearing

Published on 12 February 2024. By Keziah Mastin, Associate

Signpost pointing in different directions

In M Campbell v HMRC [2023] UKUT 265 (TCC) the Upper Tribunal (Tax chamber) remitted the taxpayers' appeals back to the First-tier Tribunal to consider the liability to capital gains tax, after the taxpayer flipped four residential properties.

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Perspective - Blog

Tribunal allows taxpayers' appeals against discovery assessments

Published on 05 February 2024. By Liam McKay, Senior Associate

Signpost pointing in different directions

In Smith v HMRC [2023] UKFTT 00912 (TC), the First-tier Tribunal (FTT) allowed the taxpayers' appeals against discovery assessments, finding that a transfer of goodwill did not amount to a distribution under section 1000, Corporation Tax Act 2010 (CTA), because the goodwill was owned personally by the taxpayers.

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Perspective - Publication

Tax Bites - January 2024

Published on 31 January 2024. By Adam Craggs, Partner

Signpost pointing in different directions

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

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Perspective - Blog

AIM higher!

Published on 30 January 2024. By Harry Smith, Senior Associate

Signpost pointing in different directions

In Graham Chisnall and Others v HMRC [2023] UKFTT 857 (TC), the First-tier Tribunal (FTT) held, in allowing the taxpayers' appeals, that evidence derived from the sale price of shares on the Alternative Investment Market (AIM) was more reliable than evidence provided by a valuer employed by HMRC.

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Perspective - Podcast

Exploring the World of AI with Olivia Dhein

30 January 2024

In this episode we discuss the hot topic of artificial intelligence. We will consider what is AI, what is a large language model and how does it work, what can AI do and not do at the moment as well as some of the potential effects AI might have in the tax world. We also take a look at the recent Tax Tribunal decision in Harber v HMRC [2023] UKFTT 1007 (TC), in which false case law was generated by AI and innocently relied upon by the taxpayer and how the Tribunal dealt with this.

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Perspective - Publication

V@ update - January 2024

Published on 24 January 2024. By Adam Craggs, Partner

Signpost pointing in different directions

Welcome to the January 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.

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Perspective - Blog

Tax Tribunal allows taxpayer's appeal against discovery assessment

Published on 18 January 2024. By Alexis Armitage, Senior Associate

Signpost pointing in different directions

FTT allows taxpayer's appeal against HMRC discovery assessment seeking to charge CGT on the disposal of a property between separating spouses.

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Perspective - Blog

Court of Appeal considers 'main purpose' test and finds in favour of taxpayer

Published on 11 January 2024. By Jasprit Singh, Senior Associate

Signpost pointing in different directions

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Perspective - Blog

Directors not liable under PLNs as HMRC failed to establish deliberate conduct by company

Published on 05 January 2024. By Keziah Mastin, Associate

Signpost pointing in different directions

In Sharon Suttle and another v HMRC [2023] UKFTT 873 (TC), the Tax Tribunal allowed the taxpayers' appeals against Personal Liability Notices (PLNs) on the basis that the company did not make a deliberate inaccuracy in its returns.

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