Tax UK Notes

Insight alert: Exploring Labour's election tax plans

High Court finds no duty owed to investors by barrister advising scheme promoter

Judgment was handed down by Zacaroli J today in McClean & Others v Thornhill [2022] EWHC 457 (Ch). The decision will be of interest to …

When can a partial closure notice be required?

In Embiricos v HMRC [2022] EWCA Civ 3, the Court of Appeal confirmed that where HMRC's conclusion in respect of a matter enquired into has …

Estoppel by convention and notices of enquiry

In Tinkler v HMRC [2021] UKSC 39, the Supreme Court held that a taxpayer (Mr Tinkler) was prevented (estopped by convention) from challenging the …

Supreme Court provides guidance on Follower Notices

In R (on the application of Haworth) v HMRC [2021] UKSC 25, the Supreme Court has upheld the Court of Appeal's decision quashing a follower notice …

Supreme Court rules on what is "deliberate"

The Supreme Court has dismissed the Revenue's appeal in HMRC v Tooth [2021] UKSC 17, a case concerning whether a "discovery assessment" was …

Mutual mistake and rectification: lessons to be learned from MV Promotions v TMG

A number of important points emerge from the recent decision in MV Promotions Limited and Micheal Vaughan v Telegraph Media Group Limited and HMRC [2020] …

High Court offers sympathy but no remedy to trustee facing unexpected tax bill

In Mackay v Wesley [2020] EWHC 1215 (Ch), the Claimant, who was instructed by her father to become a trustee of a family trust as …

Tax Treaty Interpretation: The Limits of Fiction

In Fowler v HMRC [2020] UKSC 22, the Supreme Court determined that a statutory fiction created by a deeming provision of UK tax law did not …

HSF Trust Companies Survey - Tax Insights

We asked trust companies questions about the most significant risk and compliance issues they face. The survey mapped which specific tax compliance …

Rapid resolution of domicile disputes: be careful what you wish for

In Henkes v HMRC [2020] UKFTT 7645 (“Henkes”), the First-tier (Tax) Tribunal (“the Tribunal”) held that (a) …

HMRC guidance on statutory residence test and COVID-19

HMRC has updated its guidance on the Statutory Residence Test (“SRT”) to extend the exceptional circumstances disregard to cover COVID-19. …