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13 results found

Article

RPC | United Kingdom | 22 Oct 2014

FTT prevents HMRC from having two bites of the cherry!

In Lady Henrietta Pearson v HMRC 2014 UKFTT 890 (TC), the First-tier Tribunal (Tax Chamber) ('FTT') concluded that HMRC had "ignored" its previous

Article

RPC | United Kingdom | 6 Aug 2014

Trading "with a view to the making of a profit" - an objective or subjective test?

In Beacon Estates (Chepstow) Ltd v HMRC 2014 UKFTT 686 (TC), the First-tier Tribunal (Tax Chamber) ('FTT') allowed the taxpayer's appeal, holding

Article

RPC | United Kingdom | 10 Jul 2014

Taxpayer succeeds in loss relief claim

In Hamilton & Kinneil (Archerfield) Ltd and others v HMRC 2014 UKFTT 350 (TC), the First-tier Tribunal (Tax Chamber) ('FTT') held that a company

Article

RPC | United Kingdom | 18 Jun 2014

Information notices suspended by FTT to allow the taxpayers to seek judicial review

In Whitefields Golf Club Ltd & Others v HMRC, the First-tier Tribunal (Tax Chamber) ('FTT') suspended the effect of its decision in relation to

Article

RPC | United Kingdom | 19 Mar 2014

HMRC loses FURBS appeal

In HMRC v Forde and McHugh Limited 2014 UKSC 14, the Supreme Court has dismissed HMRC's appeal and reinstated the decision of the Upper Tribunal

Article

RPC | United Kingdom | 5 Feb 2014

Further guidance from the Tribunal on closure notices: long stop dates

We recently blogged about the timing of closure notices: "Tribunal directs HMRC to issue Closure Notice". In the case to which that blog related, the

Article

RPC | United Kingdom | 13 Nov 2013

Tribunal prevents HMRC from ‘relitigating’ the case in Rosenbaum v HMRC

In Rosenbaum v HMRC the First-tier Tribunal ('FTT') recently considered the circumstances in which it can set aside a decision under Rule 38 of

Article

RPC | United Kingdom | 17 Oct 2013

Taxpayer's appeal allowed as HMRC has not made a discovery determination in time

The recent First-tier Tribunal ('FTT') case of Nijjar Dairies Ltd v HMRC dealt with two matters. The first was a preliminary issue of whether a

Article

RPC | United Kingdom | 11 Sep 2013

Taxpayer wins appeal notwithstanding mistimed implementation

The First-tier Tribunal ('FTT') has recently ruled in favour of a taxpayer in relation to a consultancy fee purportedly paid to a company which was

Article

RPC | United Kingdom | 27 Jun 2013

When should a penalty be suspended?

The First-tier Tribunal ('FTT') has allowed the taxpayer's appeal in Testa v HMRC, against HMRC's refusal to suspend a penalty imposed under

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