Tax Take
Court of Appeal considers burden of proof in penalty appeals
In HMRC v Sintra Global Inc and another [2025] EWCA Civ 1661, the Court of Appeal decided that taxpayers, not HMRC, must prove they are not liable to the underlying tax when challenging penalties.
Read moreTax Bites - March 2026
Welcome to our March 2026 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read morePurchase of an apartment and storage unit was a mixed-use acquisition for SDLT purposes
In Raj Sehgal and another v HMRC [2025] UKFTT 1439 (TC), the First-tier Tribunal (FTT) held that a storage unit acquired together with a luxury apartment were separate land transactions and the mixed/non-residential rates of SDLT applied to the purchase.
Read moreVAT update February 2026
Welcome to the February 2026 edition of RPC's VAT update, your monthly source for news and insightful analysis from the world of VAT.
Read moreCustoms and Excise quarterly update – February 2026
Welcome to the February 2026 edition of RPC's Customs and excise quarterly update.
Read moreCourt of Appeal finds expenses paid by an umbrella company were taxable
In Mainpay Ltd v HMRC [2025] EWCA Civ 1290, the Court of Appeal found that travel and subsistence expenses paid by an umbrella company to its employees were taxable.
Read moreStatutory demands relating to disguised remuneration schemes
We have recently successfully assisted several clients who had previously utilised arrangements involving Curzon Capital Limited. The arrangements involved payments being routed through a trust and received as “loans”.
Read moreTribunal dismisses HMRC's appeal and confirms no general principle of reciprocal disclosure
This article provides an overview of key developments in contentious tax in 2025.
Read moreUpper Tribunal considers 'wholly and exclusively' test in the context of SDLT and ATED
In Investment and Securities Trust Ltd v HMRC [2025] UKUT 00331 (TCC), the Upper Tribunal denied SDLT relief, holding an option held by a property development company was not acquired 'wholly and exclusively' for property development purposes, but allowed the taxpayer’s appeal in relation to ATED relief.
Read moreTaxing Matters: HMRC's approach to supply chain fraud, with Joshua Carey of Devereux Chambers
In this episode of RPC’s Taxing Matters podcast, Michelle Sloane, Partner in our Tax, Investigations and Financial Crime team, is joined by Joshua Carey of Devereux Chambers to explore HMRC’s increasingly robust approach to supply chain fraud, and what this means in practice for businesses.
Read moreTax Bites - February 2026
Welcome to our February 2026 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTracking crypto-asset tax rules in 2026 and beyond
This article provides an overview of key developments in the taxation of crypto-assets.
Read moreVAT update January 2026
Welcome to the January 2026 edition of RPC's VAT update, your monthly source for news and insightful analysis from the world of VAT.
Read moreShare buy-back satisfied 'trade benefit' test and was taxable as a capital gain and not a distribution
In Boulting v HMRC [2025] UKFTT 1272 (TC), the First-tier Tribunal found that a share buy-back satisfied the "trade benefit" test in section 1033 of the Corporation Tax Act 2010.
Read moreA 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.
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