Tax Take
Tribunal finds that film partnerships were carrying on a genuine trade
Tax tribunal finds that film partnerships were carrying on a genuine trade and that the equity funded portion of their film production expenditure qualified for tax relief, but the debt-financed portion did not.
Read moreVAT update August 2026
Welcome to the August 2026 edition of RPC's VAT update, your monthly source for news and analysis from the world of VAT.
Read moreCustoms and Excise quarterly update – August 2026
Welcome to the August 2026 edition of RPC's Customs and Excise quarterly update.
Read moreFull-time whistle blown in football referees employment status case
In Professional Game Match Officials Ltd v HMRC [2026] UKFTT 654 (TC), the First-tier Tribunal allowed the taxpayer's appeal and held that football referees' individual match engagements were contracts for services and not contracts of employment.
Read moreTaxing Matters: Whistleblowing under the Strengthened Reward Scheme, with Adam Craggs
In this episode of Taxing Matters, host Michelle Sloane is joined by RPC's Head of Tax, Investigations and Financial Crime, Adam Craggs to examine the merits and drawbacks of the Strengthened Reward Scheme (SRS).
Read moreStatutory Residence Test - Tribunal rejects HMRCs arguments
Tax Tribunal confirms that taxpayer was non-resident under the statutory residence test as three days fell within the transit exception and one day within the exceptional circumstances exception.
Read moreCourt of Appeal confirms loan from EBT does not constitute taxable earnings
In HMRC v MR Currell Ltd [2026] EWCA Civ 445, the Court of Appeal upheld the decision of the Upper Tribunal and confirmed that a genuine loan, which was expected to be repaid, did not constitute taxable earnings under section 62, Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003). The case was distinguishable from RFC 2012 plc (in liquidation) (formerly The Rangers Football Club plc) v Advocate General for Scotland [2017] STC 155 (Rangers).
Read moreTax Bites - August 2026
Welcome to our August 2026 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreContentious Tax Quarterly Review – Summer 2026
This Contentious Tax Review provides commentary on a number of recent important decisions in the tax disputes arena concerning: (1) HMRC's increasing use of strike out and the First-tier Tribunal's approach to such applications; (2) costs incurred as a result of HMRC's unreasonable conduct before an appeal is filed; and (3) the difficulties faced by taxpayers when pursuing applications for disclosure against HMRC.
Read moreCorporate tax update - May and June 2026
Welcome to the latest edition of our Corporate Tax Update covering key developments from May and June 2026, written by members of RPC's tax team.
Read moreVAT update July 2026
Welcome to the July 2026 edition of RPC's VAT update, your monthly source for news and analysis from the world of VAT.
Read moreNew taxpayer duty to correct errors in tax returns
On 13 July 2026, HMRC published draft legislation for inclusion in the Finance Bill 2027 which, if enacted, will introduce a new duty on taxpayers to correct errors identified in their tax returns.
Read moreHMRC's appeal dismissed: interest payment not caught by anti-abuse provision in UK-Ireland double tax treaty
Court of Appeal confirms that interest payment is not caught by the anti-abuse provisions in the UK-Ireland double tax treaty.
Read moreSupreme Court confirms capital allowances not available for expenditure on windfarm
In Orsted West of Duddon Sands (UK) Ltd and others v HMRC [2026] UKSC 12, the Supreme Court held that expenditure incurred on studies and surveys informing the design and installation of windfarms do not qualify for capital allowances due to their "tangential" connection with the diminishing value of the windfarm assets.
Read moreUpper Tribunal allows taxpayer's appeal in asset hive down case
In CATS North Sea Ltd v HMRC [2026] UKUT 142 (TCC), the Upper Tribunal considered oil ring-fence and transfer of trade provisions and found that the taxpayer's calculation of its balancing charge was correct. The decision turned on the application of transfer of trade provisions in Chapter 1 of Part 22 of the Corporation Tax Act 2010 and the extent to which those provisions took account of ring-fencing provisions in respect of oil-related activities in Part 8 of the Corporation Tax Act 2010.
Read moreUT confirms that HMRC cannot adopt a 'blanket' approach when issuing a discovery assessment
In HMRC v Harte [2026] UKUT 112 (TCC), the Upper Tribunal rejected HMRC’s single assessment approach, confirming that the gateway in section 29(3), Taxes Management Act 1970, must be satisfied for each distinct loss of tax 'discovered', so a deliberate or careless insufficiency cannot validate the inclusion of less culpable insufficiencies or extend the time limits in section 36, Taxes Management Act 1970, to the assessment as a whole.
Read moreTax Bites - July 2026
Welcome to our July 2026 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTribunal upholds £1m penalty for breach of a stop notice
In Countrywide Partners Ltd v HMRC [2026] UKFTT 357 (TC), the First-tier Tribunal dismissed Countrywide Partners Ltd's appeal against a £1m penalty imposed by HMRC, pursuant to paragraph 2(1), Schedule 35, FA 2014, for breach of a stop notice issued in relation to the promotion of a tax avoidance scheme, pursuant to section 236A, Finance Act 2014.
Read moreVAT update June 2026
Welcome to the June 2026 edition of RPC's VAT update, your monthly source for news and analysis from the world of VAT.
Read moreTribunal allows appeal and confirms unused trade losses can be reallocated to alternative reliefs
In Lester v HMRC [2026] UKFTT 00323 (TC), the FTT confirmed that unused trade losses may be redirected to alternative reliefs, and that the appeal was valid despite HMRC's failure to issue a formal notice of enquiry.
Read moreTribunal allows appeal and finds that payments made by a charity were repayments of a loan
In Newpier Charity Ltd v HMRC [2026] UKFTT 00321 (TC), the First-tier Tribunal considered whether payments made by a charity company were repayments of a loan or non-charitable expenditure, for the purposes of section 496(1)(d), Corporation Tax Act 2010.
Read moreTax Bites - June 2026
Welcome to our June 2026 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTribunal sets aside £2 million director's liability notice as an abuse of process
In Trees v HMRC [2026] UKUT 92 (TCC), the Upper Tribunal allowed the taxpayer's appeal against a Director's Liability Notice, finding that HMRC's conduct was an abuse of process as it had based a dishonesty penalty on findings from a prior hearing in which no allegation of dishonesty had been advanced by HMRC.
Read moreEMI reforms now in force: wider eligibility and longer option periods
Reforms to the Enterprise Management Incentive (EMI) regime took effect from 6 April 2026, bringing welcome changes that should mean favourable EMI tax treatment is open to businesses at later stages in their growth cycle.
Read moreUpper Tribunal considers disallowance of imported losses
In UK Care No 1 Limited v HMRC [2026] UKUT 00090 (TCC), the Upper Tribunal partially allowed the taxpayer's appeal regarding the "imported loss" rule under the UK's loan relationship regime.
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