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United Kingdom Case Law

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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 [2021] UKFTT 390

Hargreaves Property Holdings Ltd v Revenue & Customs (CORPORATION TAX - whether interest paid by a UK resident company out of assets)

Hargreaves Property Holdings Ltd v Revenue & Customs (CORPORATION TAX - whether interest paid by a UK resident company out of assets) [2021] UKFTT 390 (TC) (02 November 2021)

The tribunal held that interest had a UK source, was yearly in nature, and withholding exemptions did not apply on the facts. The appeal was dismissed.

  • Withholding tax
  • Interest payments
  • Double tax treaty
  • Source of interest
  • Loan arrangements
  • Corporation-tax
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Tax law [2021] UKFTT 390 (TC)

Hargreaves Property Holdings Ltd v Revenue & Customs (CORPORATION TAX - whether interest paid by a UK resident company out of assets)

Hargreaves Property Holdings Ltd v Revenue & Customs (CORPORATION TAX - whether interest paid by a UK resident company out of assets) [2021] UKFTT 390 (TC) (02 November 2021)

The First-tier Tribunal held that the interest had a UK source, the loans were yearly in nature, treaty relief required a claim and direction, and the exemption was unavailable.

  • Interest withholding tax
  • Source of interest
  • Double tax treaty
  • Beneficial entitlement
  • Loan arrangements
  • Corporation-tax
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United Kingdom decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.