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England and Wales decisions
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The Tribunal dismissed ESL’s appeal against HMRC closure notices, finding its waste-handling projects did not amount to R&D and the claimed expenditure was not proved.
The tribunal dismissed Beer Express Ltd’s appeal against HMRC’s refusal of R&D tax relief, finding no cogent evidence of qualifying scientific or technological uncertainty.
The Tribunal found on the balance of probabilities that Ambertown was the creditor and the payments in 2017 and 2019 were repayments of the loan, thus excluded from non-charitable expenditure under s 498(2)(c) CTA 2010; closure notices treating them as taxable non-charitable expenditure were set aside.
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The appellant acquired an intangible fixed asset for continuing use in its activities, and correctly claimed amortisation deductions in accordance with GAAP. The asset was transferred and controlled by the appellant, and the arrangements constituted a valid acquisition and exploitation of an intangible asset. HMRC's discovery assessments for certain periods were invalid as the extended time limit did not apply; there was no loss of tax brought about by careless conduct.
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The tribunal held that donations made by Anston Investments to its charity parent were qualifying charitable donations and upheld the appeal.
Muller UK and Ireland Group LLP & Ors v Commissioners for His Majesty's Revenue and Customs [2026] EWCA Civ 248 (11 March 2026)
The Court of Appeal held that LLP profit deeming rules required attribution of ownership and control for related-party analysis, so amortisation debits were disallowed.
Upper Tribunal tax appeal on imported losses and loan relationship debits. It held section 327 can apply to expenses, but allowed relief for unamortised issue costs and discount.
MPHL did not acquire control over the operations of the Milton Park care home business and did not retain the risks and rewards of that business following the formation of MCP. The substance of the arrangements, when viewed as a whole, demonstrates that control over the business resided with the partnership and its Managing Partner, not MPHL. Therefore, MPHL was not entitled to recognise purchased goodwill in its accounts under UK GAAP.
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The Court of Appeal dismissed taxpayers’ challenge to denial of deductions for unfunded pension provisions, holding the arrangements were mainly tax-driven and not wholly and exclusively for trade.
The Upper Tribunal granted Syngenta Holdings Limited limited permission to appeal against an FTT decision on unallowable purpose and apportionment under the Corporation Tax Act 2009.
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