Tax Take
HMRC issues guidance on new Prohibition of Promotion regime
HMRC has issued guidance on the new Prohibition of Promotion (POP) regime contained in Part 6 of the Finance Act 2026, highlighting the significant penalties that can apply to those who promote certain tax avoidance arrangements.
Read moreHMRC's New Anti-Avoidance Information Powers
HMRC has published guidance on the new anti-avoidance information notices (AAINs), contained in Part 6 of the Finance Act 2026. The new powers give HMRC significantly broader information-gathering powers when investigating the promotion or facilitation of tax avoidance.
Read moreUK prize draws: HMRC scrutiny of VAT treatment
HMRC is scrutinising the VAT treatment adopted by operators of prize draws offering both paid and free entry routes.
Read moreUpper Tribunal dismisses HMRC's appeal and confirms that taxpayers were carrying on a business with a view to profit
In HMRC v GCH Corporation Ltd and others [2026] UKUT 00219 (TCC), the Upper Tribunal dismissed HMRC's appeal and confirmed that GCH Active LLP was carrying on a business with a view to profit, for the purposes of section 59A, Taxation of Chargeable Gains Act 1992, at the time certain loan notes were transferred to it. As the requirements of section 59A were satisfied, the transfers were capital contributions, rather than disposals, and no Chargeable Gains Tax liability arose.
Read moreTax Bites - October 2026
Welcome to our October 2026 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreHMRC’s new anti-avoidance information notice powers
HMRC has published guidance on the new anti-avoidance information notices (AAINs), contained in Part 6 of the Finance Act 2026. The new powers give HMRC significantly broader information-gathering powers when investigating the promotion or facilitation of tax avoidance.
Read moreUT remits £880m loan relationship dispute back to the FTT
In Barclays Bank plc v HMRC [2026] UKUT 212, the Upper Tribunal held that the First-tier Tribunal had erred in law when determining whether £3 billion paid for reserve capital instruments was attributable wholly to those instruments or partly to warrants issued by Barclays plc, as it had taken into account irrelevant considerations. The Upper Tribunal remitted the case back to the First-tier Tribunal to reconsider its decision.
Read moreVAT update September 2026
Welcome to the September 2026 edition of RPC's VAT update, your monthly source for news and analysis from the world of VAT.
Read moreUK ‘Windfall’ Bank Tax Would Worsen an Already Complex System
Adam Craggs and Jasprit Singh consider the impact of a new tax on UK banks.
Read moreTribunal limits HMRC's Schedule 36 powers in transfer pricing case
Tax Tribunal allow taxpayer's appeal against a Schedule 36 information notice, issued by HMRC in a transfer pricing enquiry, as the documents requested were not reasonably required to check the taxpayers tax position and in any event were not in the taxpayer's possession or power.
Read moreHMRC prevented from imposing late payment penalties following reallocation of earlier payments made on time
In Herrmann v HMRC [2026] UKFTT 715 (TC), the First-tier Tribunal allowed the taxpayer’s appeals, holding that subsequent reallocation of payments could not, retrospectively, create late payment where the relevant tax had been paid by the statutory trigger dates and HMRC could not issue late payment penalties and surcharges under paragraphs 1-3, Schedule 56, Finance Act 2009 and section 59C, Taxes Management Act 1970.
Read moreIs HMRC looking at your crypto activity?
HMRC’s latest published statistics show continued growth in both the number of taxpayers holding cryptoassets and associated tax receipts, making cryptoasset holders an increasingly prominent target for HMRC.
Read moreTax Bites - September 2026
Welcome to our September 2026 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTribunal 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.
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