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Tax law [2026] UKFTT 517 (TC)

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))

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.

  • Income tax
  • Share loss relief
  • Anti-avoidance
  • Capital gains tax
  • Qualifying trade
  • Loan arrangements
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Tax law [2026] UKFTT 516 (TC)

The Personal Representatives of Mukesh Sehgal & Anor v Revenue and Customs (Capital gains tax - situs of assets when disposal made - whether loan notes "registered" in Jersey at the time of redemption - meaning of "register" and "registered" for the purposes of s.275(1)(e) TCGA - whether penalties for negligent delivery of incorrect returns under s.95 TMA should be upheld)

The Personal Representatives of Mukesh Sehgal & Anor v Revenue and Customs (Capital gains tax - situs of assets when disposal made - whether loan notes "registered" in Jersey at the time of redemption - meaning of "register" and "registered" for the purposes of s.275(1)(e) TCGA - whether penalties for negligent delivery of incorrect returns under s.95 TMA should be upheld) [2026] UKFTT 516 (TC) (01 April 2026)

The tribunal held loan notes were not registered in Jersey for CGT situs purposes, but it set aside penalties because the taxpayers had relied reasonably on professional advice.

  • Capital gains tax
  • Situs of assets
  • Loan notes
  • Penalties for incorrect returns
  • Negligence in tax returns
  • Capital-gains-tax
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Tax law [2026] UKFTT 517

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))

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.

  • Income tax
  • Share loss relief
  • Anti-avoidance
  • Capital gains tax
  • Qualifying trade
  • Share-loss-relief
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Tax law [2026] UKFTT 516

The Personal Representatives of Mukesh Sehgal & Anor v Revenue and Customs (Capital gains tax - situs of assets when disposal made - whether loan notes "registered" in Jersey at the time of redemption - meaning of "register" and "registered" for the purposes of s.275(1)(e) TCGA - whether penalties for negligent delivery of incorrect returns under s.95 TMA should be upheld)

The Personal Representatives of Mukesh Sehgal & Anor v Revenue and Customs (Capital gains tax - situs of assets when disposal made - whether loan notes "registered" in Jersey at the time of redemption - meaning of "register" and "registered" for the purposes of s.275(1)(e) TCGA - whether penalties for negligent delivery of incorrect returns under s.95 TMA should be upheld) [2026] UKFTT 516 (TC) (01 April 2026)

The Tribunal held loan notes were not registered in Jersey for CGT situs purposes, but it set aside negligence penalties because the appellants reasonably relied on professional advice.

  • Capital gains tax
  • Situs of assets
  • Loan notes
  • Negligence penalties
  • Tax returns
  • Non-uk domicile
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Tax law [2026] UKFTT 324

Coopervision Lens Care Ltd v Revenue and Customs (INCOME TAX - whether sums received on the sale of shares are taxable as employment income under Chapter 3D of Part 7 to the Income Tax (Earnings and Pensions) Act 2003)

Coopervision Lens Care Ltd v Revenue and Customs (INCOME TAX - whether sums received on the sale of shares are taxable as employment income under Chapter 3D of Part 7 to the Income Tax (Earnings and Pensions) Act 2003) [2026] UKFTT 324 (TC) (2 March 2026)

The tribunal held that most share-sale proceeds were taxable as employment income under ITEPA Chapter 3D, with the appeal succeeding only for the Fourth Shares.

  • Income tax
  • Employment income
  • Paye regulations
  • National insurance contributions
  • Employment-related securities
  • Capital gains tax
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Tax law [2026] UKFTT 324 (TC)

Coopervision Lens Care Ltd v Revenue and Customs (INCOME TAX - whether sums received on the sale of shares are taxable as employment income under Chapter 3D of Part 7 to the Income Tax (Earnings and Pensions) Act 2003)

Coopervision Lens Care Ltd v Revenue and Customs (INCOME TAX - whether sums received on the sale of shares are taxable as employment income under Chapter 3D of Part 7 to the Income Tax (Earnings and Pensions) Act 2003) [2026] UKFTT 324 (TC) (2 March 2026)

The tribunal held that most share-sale proceeds were taxable as employment income under ITEPA 2003, and that the company was careless, but excluded the Fourth Shares.

  • Income tax
  • Employment-related securities
  • Paye regulations
  • National insurance contributions
  • Capital gains tax
  • Statutory interpretation
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Tax law [2026] UKUT 25 (TCC)

Holden v Revenue And Customs (INCOME TAX AND CAPITAL GAINS TAX - Limited Liability Partnership - whether amounts identified as "capital interests" were income or capital)

Holden v Revenue And Customs (INCOME TAX AND CAPITAL GAINS TAX - Limited Liability Partnership - whether amounts identified as "capital interests" were income or capital) [2026] UKUT 25 (TCC) (20 January 2026)

The Upper Tribunal held that BCG LLP “capital interests” were not genuine capital interests and upheld miscellaneous income tax treatment.

  • Income tax
  • Capital gains tax
  • Limited liability partnerships
  • Mixed member partnership rules
  • Miscellaneous income
  • Occupational income
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Tax law [2026] UKFTT 125 (TC)

Kearney v Revenue and Customs (CAPITAL GAINS TAX - whether individual resident in the UK during the relevant period on common law (pre-Finance Act 2013) principles)

Kearney v Revenue and Customs (CAPITAL GAINS TAX - whether individual resident in the UK during the relevant period on common law (pre-Finance Act 2013) principles) [2026] UKFTT 125 (TC) (14 January 2026)

The Tribunal held that Mr Kearney remained UK resident, upheld HMRC’s discovery assessments, and found his returns careless, reducing penalties.

  • Capital gains tax
  • Tax residence
  • Discovery assessments
  • Negligence in tax returns
  • Penalties for incorrect returns
  • Tax-residence
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Tax law [2026] UKFTT 125

Kearney v Revenue and Customs (CAPITAL GAINS TAX - whether individual resident in the UK during the relevant period on common law (pre-Finance Act 2013) principles)

Kearney v Revenue and Customs (CAPITAL GAINS TAX - whether individual resident in the UK during the relevant period on common law (pre-Finance Act 2013) principles) [2026] UKFTT 125 (TC) (14 January 2026)

The tribunal held Mr Kearney remained UK resident under pre-2013 common law, upheld HMRC’s discovery assessments, and sustained penalties with reductions.

  • Capital gains tax
  • Tax residence
  • Discovery assessments
  • Negligence in tax returns
  • Penalties for incorrect returns
  • Tax-residence
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Tax law [2025] UKFTT 1272

Boulting v Revenue and Customs (CAPITAL GAINS TAX - company purchase of own shares - part of related arrangements which led to removal of director/shareholder - whether purchase of own shares was for the purpose of the benefit of a relevant trade)

Boulting v Revenue and Customs (CAPITAL GAINS TAX - company purchase of own shares - part of related arrangements which led to removal of director/shareholder - whether purchase of own shares was for the purpose of the benefit of a relevant trade) [2025] UKFTT 1272 (TC) (24 October 2025)

The tribunal held that a company’s purchase of Mr Boulting’s shares was mainly to benefit the trade by resolving management disputes and enabling investment.

  • Capital gains tax
  • Company purchase of own shares
  • Entrepreneurs relief
  • Distribution vs capital gain
  • Statutory interpretation
  • Capital-gains-tax
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