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United Kingdom decisions
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The Privy Council held that dividends paid by Methanex Trinidad to its Barbados holding company were genuine, not artificial or fictitious, and qualified for treaty relief.
Akhtar v Revenue and Customs [2025] UKFTT 395 (TC) (02 April 2025)
The Tribunal upheld discovery assessments in part, finding some unexplained deposits were untaxed business withdrawals, while accepting certain property funds came from third parties.
Akhtar v Revenue and Customs [2025] UKFTT 395 (TC) (02 April 2025)
The tribunal upheld discovery assessments in part, finding some unexplained deposits were untaxed company withdrawals, but others came from third parties and some properties were held on trust.
Rooke v Revenue and Customs (CAPITAL GAINS TAX - claim for overpayment relief - appropriate calculation of allowable costs) [2024] UKFTT 403 (TC) (09 May 2024)
The Tribunal dismissed Mrs Rooke’s overpayment relief appeal, holding that her allowable costs were limited to actual acquisition costs and that private residence relief covered 21 months.
Raveendran v Revenue And Customs (Constructive trust) [2024] UKFTT 273 (TC) (03 April 2024)
The Tribunal allowed a tax appeal after finding the appellant held property on trust for his brother and was not the beneficial owner, though the discovery assessment itself was valid.
Raveendran v Revenue And Customs (Constructive trust) [2024] UKFTT 273 (TC) (03 April 2024)
The Tribunal upheld a discovery assessment but found the property was held on trust for the appellant’s brother, so the appellant was not the beneficial owner.
NEWFIELD v Revenue & Customs (CAPITAL GAINS TAX - disposal of a property which had been beneficially owned by the Appellant's trustee in bankruptcy for some part of the period between the Appellant's initial acquisition and completion of the disposal of the property) [2024] UKFTT 116 (TC) (26 January 2024)
The tribunal held that section 66 TCGA 1992 deemed the taxpayer to own the property throughout bankruptcy, and rejected promissory estoppel.
NEWFIELD v Revenue & Customs (CAPITAL GAINS TAX - disposal of a property which had been beneficially owned by the Appellant's trustee in bankruptcy for some part of the period between the Appellant's initial acquisition and completion of the disposal of the property) [2024] UKFTT 116 (TC) (26 January 2024)
The Tribunal upheld a capital gains tax assessment on the sale of a property after bankruptcy, holding that section 66 TCGA 1992 deemed continuous ownership and that estoppel did not apply.
ASHTONS LEGAL (A PARTNERSHIP) v Revenue & Customs (VAT - to whom was the supply of the leases made? - contractual leases or commercial and economic reality) [2022] UKFTT 422 (TC) (15 November 2022)
The tribunal held that ASHTONS LEGAL, not a dormant nominee company, was the true recipient of leased premises for VAT purposes and could recover input tax.
ASHTONS LEGAL (A PARTNERSHIP) v Revenue & Customs (VAT - to whom was the supply of the leases made? - contractual leases or commercial and economic reality) [2022] UKFTT 422 (TC) (15 November 2022)
The tribunal held that a partnership, not its dormant nominee company, was the true recipient of leased premises for VAT purposes and could recover input tax.
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