Nicholas Fernyhough

RPC

Articles

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High Court considers the Ramsay principle in the context of a proposed scheme of arrangement

United Kingdom - November 23 2016 In Re Home Retail Group Plc, the High Court considered the so-called Ramsay principle of purposive construction in deciding whether a cancellation…

N Brown Group Plc: Tribunal confirms there is no going back once a taxpayer has opted out of the costs regime

United Kingdom - September 28 2016 In N Brown Group Plc and Another v HMRC [2016] UKFTT 445 (TC), the First-tier Tribunal (FTT), has confirmed that it did not have the power to permit a…

SIPP scheme administrator avoids 'pension liberation' tax charge

United Kingdom - August 17 2016 In a recent case the First-tier Tribunal (FTT) has found that HMRC was wrong to refuse Sippchoice's application for the discharge of liability to…

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

United Kingdom - January 20 2016 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'…

Tribunal considers Tower M Cashback and scope of 'conclusion' in closure notice

United Kingdom - October 16 2015 In B & K Lavery Property Trading Partnership v HMRC, the First-tier Tribunal (FTT) declined the Appellant's application to strike out HMRC's case…