In Sally Judges (as representative for the late R Young) v HMRC [2022] UKFTT 77 (TC), the FTT found that the taxpayer was entitled to adopt a more beneficial method of calculating top slicing relief and disagreed with HMRC who had argued that amendments made by the Finance Act 2020 to the Income Tax (Trading and Other Income) Act 2005, which prevented the more beneficial method of calculation being adopted, applied retrospectively. The FTT did not look favourably upon HMRC's attempt (by reference to the Explanatory Notes to the legislation) to effectively substitute its own "wishes and desires" relating to the scope of the legislation, for the will of Parliament.  You can read our commentary on the decision here.