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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....
ScottishPower: Are fines and penalties deductible as trading expenses?
I always think that the first tax rule that people learn is the one that prevents a trader from claiming a deduction for...
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The case of HMRC v Yaxley: the power of a single word
The Self Assessment rules are prescriptive.
Rupert Grint and the failed tax scheme: the 'sales of occupation’ income rules
Much of the Income Tax Act 2007, Parliament might be proud to say, is perfectly normal, thank you very much....
Tribunal penalties: suspension of disbelief
In the June issue of Tax Adviser, I reported on the Cooke case (‘Two DP or not two DP, that’s the problem’), where an in...
Carvajal v HMRC: attempts to mitigate inheritance tax
Without wishing to comment on the accuracy of the general public’s perception of inheritance tax, it is probably fair to...
PGMOL v HMRC: the long-awaited decision on employment status
Exactly three years ago, in the November 2021 issue of Tax Adviser, I wrote about the Court of Appeal’s decision in the ...
The pursuit of costs: litigation processes
A fundamental aspect of the tribunals system is that a tribunal is meant to be a more accessible forum for achieving jus...
HMRC v RALC Consulting: the latest review of IR35
The so-called ‘IR35 rules’ (more strictly, the ‘intermediaries’ legislation’) were announced just over 25 years ago with...