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The Privy Council partly allowed Unicomer’s tax appeal, remitting the anti-avoidance and withholding tax issues, but dismissed the appeal on hire purchase income accrual.
Wilders v Revenue and Customs (INCOME TAX - share loss relief - whether circumstances of the investment gave rise to a loss within sections 131, 137 Income Tax Act 2007 (ITA) and section 17 Taxation of Chargeable Gains Act 1992 (TCGA) - was relief denied by and of the provisions of general or targeted anti avoidance provisions (sections 16A, 30 or 38 TCGA)) [2026] UKFTT 517 (TC) (01 April 2026)
The tribunal dismissed Mr Wilders’ appeal over share loss relief for a marine salvage investment, finding the structure triggered anti-avoidance rules.
Wilders v Revenue and Customs (INCOME TAX - share loss relief - whether circumstances of the investment gave rise to a loss within sections 131, 137 Income Tax Act 2007 (ITA) and section 17 Taxation of Chargeable Gains Act 1992 (TCGA) - was relief denied by and of the provisions of general or targeted anti avoidance provisions (sections 16A, 30 or 38 TCGA)) [2026] UKFTT 517 (TC) (01 April 2026)
The tribunal dismissed Simon Wilders’ appeal concerning share loss relief for a marine salvage investment, holding that anti-avoidance provisions denied the claimed loss.
Oscroft & Ors v Revenue and Customs (INCOME TAX - transactions in securities regime - whether distributable reserves of a wholly owned subsidiary were assets available to the parent - whether s698 provides a six year time limit for raising an assessment to make an adjustment under the regime) [2026] UKFTT 251 (TC) (12 February 2026)
The Tribunal held that subsidiary reserves could count as assets available to the parent under the transactions in securities rules, but the assessments were out of time.
Wood Group Engineering (North Sea) Ltd v Revenue and Customs (NATIONAL INSURANCE - Host Employer Provisions – Whether on the facts Appellant "made available employees" to a foreign employer) [2026] UKFTT 1607 (TC) (12 January 2026)
The Tribunal held that Wood Group Engineering (North Sea) Ltd was a host employer under the 1978 Regulations and dismissed its appeal against secondary NICs.
Wood Group Engineering (North Sea) Ltd v Revenue and Customs (NATIONAL INSURANCE - Host Employer Provisions – Whether on the facts Appellant "made available employees" to a foreign employer) [2026] UKFTT 1607 (TC) (12 January 2026)
The Tribunal held that Wood Group Engineering (North Sea) Ltd was a host employer under the 1978 Regulations and dismissed its NIC appeal.
Wood Group Engineering (North Sea) Ltd v Revenue And Customs (NATIONAL INSURANCE - Host Employer Provisions) [2025] UKFTT 1607 (TC) (22 December 2025)
The tribunal dismissed Wood Group Engineering’s appeal, holding it was a host employer liable for secondary Class 1 NICs under the 1978 Regulations.
Wood Group Engineering (North Sea) Ltd v Revenue And Customs (NATIONAL INSURANCE - Host Employer Provisions) [2025] UKFTT 1607 (TC) (22 December 2025)
The tribunal dismissed Wood Group Engineering (North Sea) Ltd’s appeal, holding it was a host employer liable for secondary Class 1 NICs under the 1978 Regulations.
Robinson & Anor v Revenue and Customs (TAMP DUTY LAND TAX - HMRC application to strike out) [2025] UKFTT 55 (TC) (03 January 2025)
The First-tier Tribunal struck out a stamp duty land tax appeal over a marketed subsale and annuity scheme, holding it had no realistic prospect of success.
Robinson & Anor v Revenue and Customs (TAMP DUTY LAND TAX - HMRC application to strike out) [2025] UKFTT 55 (TC) (03 January 2025)
The First-tier Tribunal struck out an SDLT appeal over a marketed subsale-and-annuity scheme, holding there was no qualifying subsale and that s 75A applied.
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