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Enterprise zone allowances: the basis of a ‘golden contract’
In my article ‘A golden contract’ in the February 2020 issue of Tax Adviser, I discussed the Upper Tribunal’s decision i...
Cumming-Bruce v HMRC: Enquiries into capital loss claims
Lying at the heart of the Self Assessment system is HMRC’s power of enquiry.
The availability of main residence exemption when a house is rebuilt
Although nothing can be taken for granted, there is a general assumption that no UK politician would seek to extend capi...
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Quayviews: a company penalised for submitting its RTI returns early
I suspect that few readers will disagree with the proposition that, as a matter of principle, HMRC should have the power...
The statutory residence test: defining ‘exceptional circumstances’
The circumstances underlying this case concern a series of family tragedies which I do not wish to belittle in any way....
Penetrating the obscuring mists of judicial precedent
In the December 2016 issue of Tax Adviser, my article ‘Return of the naïve’ looked at the Upper Tribunal case of Hardy v...
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....