United Kingdom Case Law

Currys Retail Ltd v Revenue and Customs (CORPORATION TAX - whether a company leaving a group was subject to a degrouping charge)

Currys Retail Ltd v Revenue and Customs (CORPORATION TAX - whether a company leaving a group was subject to a degrouping charge) [2025] UKFTT 762 (TC) (23 June 2025)

The Tribunal dismissed Currys Retail Ltd’s appeal and upheld a degrouping charge on goodwill when it left its group, finding the agreements did not dispose of the goodwill.

• Corporation tax
• Degrouping charge
• Chargeable gains
• Goodwill
• Intra-group transfers
• Statutory construction

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JD Wetherspoon PLC v Revenue and Customs (application of reduced rate to supplies of cider in the course of restaurant and catering services - whether cider fell within the exclusion)

JD Wetherspoon PLC v Revenue and Customs (application of reduced rate to supplies of cider in the course of restaurant and catering services - whether cider fell within the exclusion) [2025] UKFTT 658 (TC) (03 June 2025)

The Tribunal held cider was excluded from the reduced VAT rate for hospitality supplies, applying statutory construction and the Inco correction principle.

• Value added tax
• Reduced rate application
• Alcoholic beverages definition
• Statutory construction
• Eu fiscal neutrality
• Value-added-tax

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JD Wetherspoon PLC v Revenue and Customs (application of reduced rate to supplies of cider in the course of restaurant and catering services - whether cider fell within the exclusion)

JD Wetherspoon PLC v Revenue and Customs (application of reduced rate to supplies of cider in the course of restaurant and catering services - whether cider fell within the exclusion) [2025] UKFTT 658 (TC) (03 June 2025)

The Tribunal held that cider was excluded from the reduced VAT rate, applying the Inco principle and, alternatively, EU fiscal-neutrality rules.

• Value added tax
• Reduced rate application
• Alcoholic beverages definition
• Statutory construction
• Eu fiscal neutrality
• Value-added-tax

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Louwman v Revenue and Customs (INCOME TAX)

Louwman v Revenue and Customs (INCOME TAX) [2025] UKFTT 295 (TC) (07 March 2025)

The tribunal held that offshore income gains and accrued income profits were not protected foreign source income for a deemed UK domiciled settlor, and dismissed the appeal.

• Income tax
• Transfers of assets abroad
• Offshore income gains
• Accrued income profits
• Protected foreign source income
• Statutory construction

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Louwman v Revenue and Customs (INCOME TAX)

Louwman v Revenue and Customs (INCOME TAX) [2025] UKFTT 295 (TC) (07 March 2025)

The Tribunal held that offshore income gains and accrued income profits were not protected foreign source income for a deemed UK domiciled settlor, and dismissed the appeal.

• Income tax
• Transfers of assets abroad
• Offshore income gains
• Accrued income profits
• Protected foreign source income
• Statutory construction

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FRF (South Wales) Ltd v Revenue and Customs (CORPORATION TAX - Business Premises Renovation Allowances - conversion or renovation)

FRF (South Wales) Ltd v Revenue and Customs (CORPORATION TAX - Business Premises Renovation Allowances - conversion or renovation) [2024] UKFTT 1145 (TC) (18 December 2024)

The Tribunal held that works to a disused warehouse converted it into a Toyota car showroom and qualified for BPRA, allowing the appeal.

• Business premises renovation allowances
• Statutory construction
• Capital allowances
• Corporation tax
• Business-premises-renovation-allowances
• Capital-allowances

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FRF (South Wales) Ltd v Revenue and Customs (CORPORATION TAX - Business Premises Renovation Allowances - conversion or renovation)

FRF (South Wales) Ltd v Revenue and Customs (CORPORATION TAX - Business Premises Renovation Allowances - conversion or renovation) [2024] UKFTT 1145 (TC) (18 December 2024)

The tribunal allowed a BPRA appeal, holding that the warehouse works were a conversion. Sufficient continuity of identity remained despite major alterations.

• Corporation tax
• Capital allowances
• Business premises renovation allowances
• Statutory construction
• Business-premises-renovation-allowances
• Capital-allowances

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Louis Andre Monteil (Appellant) v Board of Inland Revenue (Respondent) (Trinidad and Tobago)

The Privy Council held that Trinidad and Tobago’s PAYE rules do not prevent an additional assessment against an employee where an employer fails to deduct tax.

• Paye provisions
• Income tax act interpretation
• Employee tax liability
• Employer obligations
• Statutory construction
• Tax-law

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Bunting v Revenue And Customs (CAPITAL GAINS TAX - entitlement to loss relief)

Bunting v Revenue And Customs (CAPITAL GAINS TAX - entitlement to loss relief) [2024] UKFTT 275 (TC) (27 March 2024)

The Tribunal allowed a capital gains tax loss-relief claim under s253 TCGA 1992 after a loan was capitalised into worthless shares, holding the debt remained outstanding and irrecoverable.

• Capital gains tax
• Loss relief
• Interpretation of s253 tcga 1992
• Loan capitalisation
• Statutory construction
• Capital-gains-tax

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Ravi Balgobin Maharaj (Appellant) v The Cabinet of the Republic of Trinidad and Tobago and another (Respondent) (Trinidad and Tobago)

The Privy Council held that amendments extending local council terms in Trinidad and Tobago did not apply to incumbent councillors and aldermen.

• Local government elections
• Democratic rights
• Retrospective legislation
• Statutory construction
• Statutory-interpretation
• Local-government-elections

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