The loss-carry back rules following an increase in earlier profits
The combined cases of Peter Lowe and Civic Environmental Systems Ltd v HMRC [2022] UKUT 84 (TCC) addressed three very di...
Embiricos: the scope of partial closure notices
The original Self-Assessment code was drafted almost 30 years ago and it might be said that its age is showing in places...
Quinn: the complexity of enhanced R&D rules
Until a couple of years ago, relief for research and development expenditure was a subject that did not attract much att...
Kunjur: Deductibility of accommodation expenses
It is well known that the deductibility of expenses for employees is much tougher than for the self-employed....
Salaried partner, hidden tax charge
It is probably a sign of my advancing years, but I still consider the advent of limited liability partnerships (LLPs) to...
Our Mutual Friend
In the November 2018 issue of Tax Adviser, my article ‘Men in Black’ considered the First-tier Tribunal’s decision in th...
The Benchdollar Question
In the June 2018 issue of Tax Adviser, my article ‘The 64-8 questi on’ considered what was then a recent decision of the...
Murphy’s Law
It is well known that the rules for obtaining a tax-allowable deduction from employment income are particularly restrict...
His Dark Materials
The so-called ‘IR35’ legislation is now 21 years old.
Tooth and consequences
I have already covered the Tooth case, twice before – the Upper Tribunal’s decision was discussed in my article ‘The hon...