Tax Take
Tribunal allows taxpayers’ appeals in principal private residence and trading dispute
In R Eyre and another v HMRC [2025] UKFTT 461 (TC), the First-tier Tribunal allowed the taxpayers' appeals against HMRC’s decision to assess income tax on the sale of a residential property, finding that the property qualified for principal private residence relief. The tribunal rejected HMRC’s argument that the transaction was an adventure in the nature of trade and found that the property qualified for principal private residence relief.
Read moreTax Bites - September 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreNavigating VAT issues in the UK care home sector
The UK care home sector faces a unique set of VAT challenges due to the blend of exempt and taxable supplies involved in its operations. Careful VAT planning and compliance are essential to avoid potential challenges from HMRC.
Read moreV@ update - August 2025
Welcome to the August 2025 edition of RPC's VAT update, your monthly source for news and insightful analysis from the world of VAT. We've refreshed the update to make it more digestible and help you find the most interesting updates – faster and with less hassle.
Read moreCustoms and excise quarterly update – August 2025
Welcome to the August 2025 edition of RPC's Customs and excise quarterly update.
Read moreTribunal orders HMRC to disclose whether it used AI in R&D claims
The First-tier Tribunal (General Regulatory Chamber) has ruled in the case of Elsbury v Information Commissioner [2025] UKFTT 915 (GRC) that HMRC must disclose whether, and if so when, it used AI in deciding to reject R&D tax credit claims.
Read moreHMRC’s transformation roadmap: what it means for tax disputes
On 21 July 2025, the government released HMRC’s long-awaited “transformation roadmap”, setting out its digital-first vision for the future of UK tax administration. The document outlines sweeping changes across HMRC’s processes - promising efficiency, greater use of automation and AI, and a modernised compliance regime.
Read moreHMRC targeting supply chain fraud - are you at risk? What every business needs to know
HMRC has significantly increased its scrutiny of supply chain integrity as part of its ongoing efforts to tackle fraud, particularly within sectors deemed high risk, such as construction, labour supply, wholesale, and import/export businesses. These sectors are particularly vulnerable due to complex subcontracting chains, cash-based payments, and the use of temporary labour.
Read moreContentious Tax Quarterly Review – Summer 2025
This Contentious Tax Review provides an update on a number of recent important decisions in the tax disputes arena as well as changes to tribunal procedure.
Read moreHMRC initiates first corporate prosecution under "failure to prevent" tax evasion laws
HM Revenue & Customs (HMRC) has initiated its first corporate prosecution under the "failure to prevent the facilitation of tax evasion" offence, introduced by the Criminal Finances Act 2017 (CFA 2017). This development marks a significant shift in HMRC's enforcement approach, which has faced mounting criticism for failing to use these powers since their introduction eight years ago.
Read moreTribunal allows taxpayer's R&D appeal
In Realbuzz Group Ltd v HMRC [2025] UKFTT 493 (TC), the Tax Tribunal allowed a taxpayer's R&D appeal confirming that HMRC could not issue a discovery assessment because the information provided by the taxpayer to HMRC before the enquiry window closed was sufficient to enable a hypothetical HMRC officer to realise that tax had been under assessed.
Read moreTax Bites - August 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTribunal allows trustee's appeal in inheritance tax case
In Accuro Trust (Switzerland) SA v HMRC [2025] UKFTT 464 (TC), the First-tier Tribunal (FTT) found that when a non-UK domiciled settlor added assets to an offshore trust and later became UK-domiciled, assets deposited after becoming UK domiciled remain “excluded property” when calculating inheritance tax (IHT).
Read moreTaxing Matters: The countdown to failure to prevent fraud is on (Part 3): Looking ahead: further developments for corporate criminal liability
From 1 September 2025, the new failure to prevent fraud offence will come into effect under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). Statutory guidance issued by the Home Office sets out the framework that large organisations should implement by September 2025, to ensure they have in place reasonable fraud prevention procedures.
Read moreV@ update - July 2025
Welcome to the July 2025 edition of RPC's V@, our monthly update which provides news and insightful analysis from the VAT world.
Read moreWhat the 'whistleblower' reward scheme means for tax compliance
The UK government has recently announced a new reward scheme will be established later this year to encourage informants to report tax fraud to HMRC. Such a reward scheme has implications for tax compliance.
Read moreNew legislation announced making recruitment agencies or end clients jointly and severally liable for PAYE and NIC
New legislation announced making recruitment agencies or end clients jointly and severally liable for PAYE and NIC
Read moreThe countdown to failure to prevent fraud is on (Part 2): What is failure to prevent fraud?
From 1 September 2025, the new failure to prevent fraud offence will come into effect under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). Statutory guidance from the Home Office sets out the framework that large organisations should implement by September 2025, to ensure they have in place reasonable fraud prevention procedures.
Read moreThe countdown to failure to prevent fraud is on (Part 1): A recap on corporate criminal liability
From 1 September 2025, the new failure to prevent fraud offence will come into effect under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). Statutory guidance from the Home Office sets out the framework that large organisations should implement by September 2025, to ensure they have in place reasonable fraud prevention procedures.
Read moreTribunal allows taxpayer's appeal in respect of overdrawn director's loan account
In Quillan v HMRC [2025] UKFTT 421 (TC) the FTT held that a director's loan was neither written off nor released in the absence of a formal acknowledgment from the company's liquidator.
Read moreHMRC's latest nudge letter campaign targets loan arrangements
HMRC is targeting taxpayers who have claimed tax relief for interest paid, or other debits relating to loans, where they suspect that one of the taxpayer's "main purposes" for entering into the loan relationship was to avoid tax.
Read moreTribunal accepts taxpayers' Ramsay argument and allows their appeals
In The Vaccine Research Ltd Partnership & Anor v HMRC [2025] UKFTT 402 (TC), the First-tier Tribunal (FTT) allowed the taxpayers' appeal, concluding that under the Ramsay principle of statutory interpretation, licence fees received as part of a tax-planning scheme, were neither annual payments nor income not otherwise charged of the partners, within sections 683 or 687 of Income Tax (Trading & Other Income) Act 2005.
Read moreHMRC directed by tribunal to issue closure notices
In Refinitiv Ltd and others v HMRC [2025] UKFTT 415 (TC), the First-tier Tribunal directed HMRC to issue closure notices on the basis it had failed to meet the burden to keep the relevant enquiries open as ongoing judicial review proceedings do not constitute "reasonable grounds" for not issuing a closure notice.
Read moreTax Bites - July 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTaxing Matters: When tax advice goes wrong: professional negligence in tax disputes
In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by colleagues Helen Kerr and Tom Wild from RPC's Professional Liability team to explore how professional negligence claims can arise during the lifecycle of a tax dispute.
Read moreUpper Tribunal dismisses IR 35 challenge
In George Mantides Ltd v HMRC [2025] UKUT 00124 (TCC), the Upper Tribunal dismissed the company's appeal against an income tax determination and national insurance decision. Whilst the UT set aside the earlier decision of the First-tier Tribunal on the basis that there were errors in the assessment of the hypothetical contract, ultimately it came to the same conclusion that the hypothetical contract was one of employment for the purposes of IR35.
Read moreV@ update - June 2025
Welcome to the May 2025 edition of RPC's V@, our monthly update which provides news and insightful analysis from the VAT world.
Read moreImproving HMRC’s Approach to Dispute Resolution
This article considers the recently launched consultation aimed at modernising HMRC’s approach to resolving tax disputes.
Read moreNo Retreat on UK Digital Services Tax – For Now
This blog considers recent speculation concerning the future of the UK's Digital Services Tax in the context of trade negotiations between the UK and the USA.
Read moreCourt of Appeal confirms pre-construction costs qualify for capital allowances
In Orsted West of Duddon Sands (UK) Ltd and others v HMRC [2025] EWCA Civ 279, the Court of Appeal held that expenditure incurred in designing windfarms and on studies informing the installation could qualify for capital allowances.
Read moreTax Bites - June 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreBlowing the whistle!
Adam Craggs and Tom Holden consider the US and Canadian 'whistleblower' models in light of the government's plans for a new reward scheme inspired by these, as well as the existing HMRC rewards scheme this initiative will complement.
Read moreCustoms and excise quarterly update – May 2025
Welcome to the May 2025 edition of RPC's Customs and excise quarterly update.
Read moreV@ update - May 2025
Welcome to the May 2025 edition of RPC's V@, our monthly update which provides news and insightful analysis from the VAT world.
Read moreContentious Tax Quarterly Review – Spring 2025
This Contentious Tax Review provides an update on a number of recent important decisions in the tax disputes arena.
Read moreFormer England captain's IR35 battle with HMRC ends in a score draw
In Bryan Robson Ltd v HMRC [2025] TC09408, the First-tier Tribunal considered the IR35 legislation in relation to ex-England footballer Bryan Robson. It found payments made for his ambassadorial role at Manchester United fell within the scope of the IR35 legislation, while payments made to him in respect of his image rights did not.
Read moreTaxing Matters: Mental Health Awareness Week: breaking down mental barriers in the mind with Jo Maughan
In this special Mental Health Awareness Week episode of Taxing Matters, host Alexis Armitage welcomes Jo Maughan, career coach and former tax director, to discuss how professionals can manage their critical inner voice and break down mental barriers in their mind.
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Read moreChallenging HMRC's Debt Management Actions - Lessons Learned from Local Fuel Ltd
Michelle Sloane and Daniel Williams consider when a private law action, rather than judicial review, is appropriate to challenge a decision taken by HMRC's debt management team.
Read moreTax Bites - May 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTribunal allows capital allowances claim for expenditure on construction of a quay wall at the Port of Liverpool
In The Mersey Docks and Harbour Company Ltd v HMRC [2024] UKFTT 1163 (TC), the First-tier Tribunal allowed the company's claim for capital allowances in respect of expenditure incurred on the construction of a quay wall at a new deep-water container terminal at the Port of Liverpool.
Read moreTaxing Matters: Tax risk for professionals and professional businesses with Thomas Slipanczewski, Associate Director at Deloitte
In this episode of Taxing Matters, Senior Associate and Taxing Matters host, Alexis Armitage is joined by Thomas Slipanczewski, who is an Associate Director at Deloitte in their tax controversy team, to discuss task risk for regulated professionals and professional businesses.
Read moreHMRC Landfill Tax Crackdown
In recent years, HMRC has markedly increased its compliance activity in relation to Landfill Tax and it is therefore important that businesses operating in this area are aware of common issues that are triggering time-consuming tax enquiries, subsequent disputes and litigation.
Read moreCriminal Offences and Prosecutions for Tax Fraud
Adam Craggs and Daniel Williams consider HMRC's approach to investigation and prosecution of various tax fraud offences, and deferred prosecution agreements and unexplained wealth orders.
Read moreV@ update - April 2025
Welcome to the April 2025 edition of RPC's V@, our monthly update which provides news and analysis from the VAT world.
Read moreCourt of Appeal confirms that compensatory payments made to settle regulatory investigations are not penalties
In ScottishPower (SCPL) Ltd and others v HMRC [2025] EWCA Civ 3, the Court of Appeal held that compensatory payments made to consumers in settlement of regulatory investigations were not penalties and therefore were deductible for corporation tax purposes.
Read moreBusiness Briefing: Navigating The New US-UK Trade Tariffs
The Trump administration has introduced sweeping tariffs on goods imported into the United States. This move is expected to cause significant disruption to global trade, with notable consequences for UK businesses. As the ripple effects unfold, understanding the scope of the tariffs and how to respond strategically will be crucial for UK businesses looking to protect their margins, adapt their operations, and plan confidently for the future.
Read moreUT allows company's appeal as payment to EBT was not earnings of its employee
In M R Currell Ltd v HMRC [2024] UKUT 00404, the Upper Tribunal set aside the First-tier Tribunal's decision and held that a payment from a company to an employee benefit trust was not taxable earnings as the facts were distinguishable from those in RFC 2012 plc (formerly The Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45.
Read moreTax Bites: April 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreJudicial review in tax disputes – an overview
Judicial review remains an important tool for taxpayers to challenge HMRC's decisions, and it is important for taxpayers and practitioners to have a clear understanding of the judicial review process.
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