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Marshmallow pies: a sticky case for VAT
The VAT treatment of food is a good example of how a simple, widely known tax rule is actually subject to considerable c...
Elden v HMRC: where procedure becomes the problem
The purpose of litigation is to enable the parties to a dispute to resolve it through an independent judicial process....
A company share buyback: the battle of Boulting
In my October 2020 article ‘On the way to the forum’, I looked at an unsuccessful judicial review claim reported as R (o...
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Powell v HMRC: Director's loan novation
This article concerns the recent case of Powell v HMRC [2025] UKFTT 528 (TC).
Medpro: the treatment of appeals filed after statutory deadlines
One of the first practical rules I learnt in tax was that appeals against assessments should be made within 30 days....
Main residence relief: the impact of non-occupancy
This is (I believe) my 250th case report for Tax Adviser and I will treat myself by writing about a case in which I was ...
Joye v HMRC: top slicing relief rules
In the March issue of Tax Adviser, I discussed the case of Sarah Yaxley v HMRC [2025] UKFTT 51 (TC) (‘The power of a...
The case of Quillan v HMRC: the dangers of a director’s loan account
I can remember the first time I saw a corporation tax assessment seeking tax on a loan to a participator....
Bunting v HMRC: claiming capital loss relief
Although debts are generally disregarded assets for the purposes of the capital gains tax legislation, this is subject t...
Harbron Recruit Ltd: the definition of employment
I remember Lord Carnwath (then ‘a “mere” Lord Justice’) addressing the London Branch of the CIOT back in about 2008....