Tax Take
A Review of Contentious Tax in 2025
This article provides an overview of key developments in contentious tax in 2025.
Read moreTribunal confirms multiple dwellings relief claim in SDLT appeal
In the case of Michelle Jacqueline Berrell & Anor v HMRC [2025] UKFTT 1067 (TC)), the First-tier Tribunal allowed the taxpayers' appeal and confirmed their claim for Multiple Dwellings Relief in respect of a house purchased with an annexe, ruling that the property comprised “at least two dwellings”. The decision offers key guidance on how shared spaces, terms of occupation and self-containment are treated for the purposes of Multiple Dwellings Relief.
Read moreWeis after the event
In granting permission for the taxpayer to bring a claim for judicial review that was significantly out of time, the High Court determined that there was good reason to extend time.
Read moreTaxing Matters: A very VATy Christmas with Philip Simpson KC from Old Square Tax Chambers
In this festive edition of Taxing Matters, RPC’s Senior Associate and Taxing Matters host, Alexis Armitage, is joined by Philip Simpson KC of Old Square Tax Chambers, well known VAT expert and part-time stand-up comedian. Together, they embark on an insightful sleigh ride through the VAT implications of classic Christmas fare, decorations, and traditions, demystifying which seasonal treats and trimmings may attract HMRC’s attention.
Read moreTribunal orders HMRC to disclose documents to taxpayers in offshore trust case
In Evans & Ors v HMRC [2025] UKFTT 1112 (TC), the First-tier Tribunal (FTT) ordered HMRC to disclose most of the documents sought by the taxpayers.
Read moreLatest SFO guidance on corporate self-reporting, cooperation and DPAs
In this article, Adam Craggs and Tom Jenkins of RPC's Tax, Investigations and Financial Crime team, consider the important guidance issued by the Serious Fraud Office in April 2025, providing information to companies on the agency's expectations relating to corporate self-reporting, cooperation during investigations and deferred prosecution agreements (DPAs).
Read moreTaxing Matters: Unpacking the complexities of tax deed claims with Jivaan Bennett of Temple Tax Chambers
In this episode of Taxing Matters, Alexis Armitage, Senior Associate in RPC’s Tax Disputes team, is joined by Jivaan Bennett of Temple Tax Chambers. Jivaan brings nearly 15 years of international experience in tax, commercial transactions, and disputes, having worked across the Caribbean, London, and New York.
Read moreTax Bites - December 2025
Welcome to December 2025 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreSFO publishes significant new guidance on evaluating corporate compliance programmes
The SFO has updated its guidance on evaluating corporate bribery and fraud crime compliance programmes to indicate when, how and why, it will evaluate those programmes across six scenarios covering prosecutions, DPAs, Bribery Act and ECCTA defences and sentencing considerations.
Read moreUpper Tribunal grants taxpayers permission to bring late appeals
In Medpro Healthcare Ltd & Another v HMRC [2025] UKUT 255 (TCC), the Upper Tribunal allowed the taxpayers’ appeals, finding that the First-tier Tribunal had failed to give adequate reasons and misapplied the Martland test.
Read moreVAT update November 2025
Welcome to the November 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 – November 2025
Welcome to the November 2025 edition of RPC's Customs and excise quarterly update.
Read moreTribunal allows expat's appeal confirming that SIPP withdrawals were not subject to UK tax
In Trevor John Masters v HMRC [2025] UKFTT 967 (TC), the First-tier Tribunal allowed the taxpayer's appeal, holding that the taxpayer's SIPP withdrawals were taxable only in Portugal under the UK–Portugal Double Tax Convention.
Read moreTaxing Matters: The Court of Appeal's decision in A Taxpayer v HMRC with Rebecca Sheldon, Old Square Tax Chambers
In this episode, Alexis Armitage, Taxing Matters host and Senior Associate at RPC, speaks with Rebecca Sheldon of Old Square Tax Chambers, about the Court of Appeal’s recent decision in A Taxpayer v HMRC, in which Rebecca was instructed on behalf of the taxpayer.
Read moreContentious Tax Quarterly Review – Autumn 2025
This Contentious Tax Review by RPC provides an update on a number of recent and important decisions in the tax disputes arena.
Read moreTribunal confirms caregiver living with parents was eligible for principal private residence relief
In Mark Campbell v HMRC [2025] UKFTT 00867, the First-tier Tribunal upheld the taxpayer’s claim for Principal Private Residence (PPR) relief on the disposal of multiple properties, accepting that the taxpayer qualified under the job-related accommodation rules whilst residing in his parents’ home to care for his father.
Read moreTax Bites - November 2025
Welcome to November 2025 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTaxpayer recovers almost 2 million in successful SDLT appeal
In Christian Peter Candy v HMRC [2025] UKFTT 416 (TC), the First-tier Tribunal (FTT) decided that Mr Candy was entitled to bring his claim for stamp duty land tax (SDLT) relief outside the 12-month window for amendments to returns, by relying on paragraph 34, Schedule 10, Finance Act 2003.
Read moreVAT update October 2025
Welcome to the October 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 moreIHT not due on failed EBT arrangement
In Tonkin v HMRC [2025] UKFTT 750 (TC), the First-tier Tribunal (FTT) allowed the taxpayer's appeal against a charge to inheritance tax (IHT) under section 94, Inheritance Act 1984 (IHTA 1984) (charge on participators in a close company), which HMRC considered had arisen as a result of an ineffective employee benefit trust (EBT) arrangement.
Read moreTaxing Matters: Top tips for tax litigation with Jonathan Davey KC from Wilberforce Chambers
In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by Jonathan Davey KC, of Wilberforce Chambers, one of the UK’s leading barristers in commercial chancery work with a particular focus on tax, trusts and property.
Read moreTribunal confirms its decision on “intangible fixed assets” preventing HMRC from reopening the issue
In Inside Track 3 LLP and Ingenious Film Partners 2 LLP v HMRC [2025] UKFTT 986, the First tier Tribunal (FTT) has issued a further decision in the long running Ingenious film partnerships litigation and has ruled in favour of the taxpayers that its earlier decision had already determined that certain rights held by the LLPs constitute intangible fixed assets for the purposes of Part 8 of the Corporation Tax Act 2009 and that HMRC cannot now reopen that issue.
Read moreTribunal serves decision on cooking alcohols which leads to HMRC policy change
In Gourmet Classic Ltd v HMRC [2025] UKFTT 00256 (TC), the First-tier Tribunal ruled that Gourmet's cooking wines (and other similar products), with a strength of 4.8% abv, qualify as foodstuffs and are exempt from excise duty.
Read moreTribunal grants taxpayer's application for disclosure against HMRC in Kittel appeal
In CIS-Pay Ltd v HMRC [2025] UKFTT 00751 (TC), the First-tier Tribunal (FTT) granted the appellant's application for disclosure of all material within HMRC's possession that might assist the appellant's case or undermine HMRC's case.
Read moreTax Bites - October 2025
Welcome to our October 2025 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreHMRC fails to establish "practice generally prevailing" in top-slicing relief dispute
In Roger Joye and David Sumners v HMRC [2025] UKFTT 664 (TC), HMRC failed to establish that its flawed method of calculating top-slicing relief was the "practice generally prevailing".
Read moreTaxing Matters: Wealth management for creatives – navigating financial planning in the entertainment industry
In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by Simon Reed, Director and wealth manager at RBC Brewin Dolphin, and head of the Entertainment, Media & Sports client segment in London. Together, they delve into the unique financial challenges faced by clients in the creative industries, including actors, musicians, and digital creators.
Read moreUpper Tribunal allows taxpayers' appeals in EIS case
In Hugh Edward Mark Osmond and Matthew Charles Allen v HMRC [2024] UKFTT 00378 (TC), the Upper Tribunal has reversed the decision of the First-tier Tribunal, concluding that the main purpose of the taxpayers in crystallising Enterprise Investment Scheme relief was not the obtaining of an income tax advantage, even though this may have been its effect.
Read moreVAT update September 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 moreCOVID voluntary repayment scheme launched – last chance to resolve liability before tougher sanctions apply
On 12 September 2025, the UK Government launched a time-limited COVID repayment window, allowing individuals and businesses to voluntarily repay financial support received during the COVID-19 pandemic, with no questions asked.
Read moreTribunal refuses HMRC permission to appeal to the Upper Tribunal against two case management decisions
In BGC Services Holdings LLP v HMRC [2025] UKFTT 700 (TC), the First-tier Tribunal (FTT) refused HMRC permission to appeal against the FTT's earlier case management decisions whereby the FTT refused HMRC's application seeking further and better particulars from the taxpayer and granted the taxpayer's application for HMRC to properly particularise its case.
Read moreTribunal 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 our September 2025 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 moreTaxing Matters: The 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.
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