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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 ...
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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...
The case of Cooke v HMRC: the problems caused by a rounding error
Entrepreneurs’ relief (now business asset disposal relief) was introduced in the Finance Act 2008 and has survived longe...
Termination of employment: when is a payment tax free?
One of the issues that has regularly featured in the case law concerning employment tax is the taxation of payments rece...
Cash-based businesses: a claim that profits were overstated
Having just passed the 20th anniversary of the first of my monthly case reports and seeing that the official publication...
Taxing discretionary gifts to employees: OOCL UK Branch v HMRC
A payment made by an employer to an employee will usually be subject to tax as employment income and, in the case of a c...
Transfer of assets abroad: the boundaries of the rules
The transfer of assets abroad legislation (variously abbreviated to ToAA and TAA) was first enacted in 1936....