Our Insights

Reversal of Inverclyde

The 2020 Budget announced provisions to reverse last year’s FTT decision in Inverclyde. In that case, HMRC denied the appellant LLPs’ claims for Business Property Renovation Allowance on the basis that the LLPs did not carry on a business with a view to a profit. 

HMRC nudge letters

HMRC continues to fight the good fight in its quest to cut down on tax avoidance and have recently been issuing further “nudge” letters to taxpayers who may have an income source or assets producing gains overseas and consequently an undisclosed outstanding UK tax liability.

ExxonMobil: FTT Decision Released

The FTT decision in Esso Exploration and Production UK Limited and others v HMRC, which relates to pre-2006 claims for Cross Border Group Relief, has now been released.

Ingenious LLPs v HMRC – Permission to appeal partially granted

In the latest instalment of the long-running dispute over various film and game investment schemes, the Court of Appeal grants partial permission for the appeal to be heard in its court.

Guidance released on new Double Tax Dispute Resolution

First Insight into HMRC’s use of Corporate Criminal Offences Powers

CJEU release its KA Deka Judgment

Private residence relief: lessons from recent case law by Senior Associate Helen McGhee

This article was originally published by the Tax Journal on 31st of January

There is more to Inverclyde than meets the eye

HMRC Business Brief on Settlement of Statutory Double Tax Relief Claims Affected by the FII and CFC Dividend GLOs