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Tax law [2026] UKFTT 663 (TC)

Smith v Revenue and Customs (INCOME TAX and VAT)

Smith v Revenue and Customs (INCOME TAX and VAT) [2026] UKFTT 663 (TC) (06 May 2026)

The Tribunal upheld HMRC’s income tax and VAT assessments and most penalties, finding the appellant continued to run the business after March 2003, but ordered recalculation where figures overcharged.

  • Discovery assessments
  • Best judgment assessments
  • Tax penalties
  • Vat registration and deregistration
  • Tax residency
  • Burden of proof
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Tax law [2026] UKFTT 663

Smith v Revenue and Customs (INCOME TAX and VAT)

Smith v Revenue and Customs (INCOME TAX and VAT) [2026] UKFTT 663 (TC) (06 May 2026)

The tribunal considered HMRC income tax and VAT assessments against a former accountant, including whether he still ran the business after a 2003 sale.

  • Income tax
  • Vat
  • Discovery assessments
  • Best judgment assessments
  • Penalties
  • Tax residency
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Tax law [2026] UKFTT 652 (TC)

Parker v Revenue and Customs (INCOME TAX - Statutory Residence Test)

Parker v Revenue and Customs (INCOME TAX - Statutory Residence Test) [2026] UKFTT 652 (TC) (01 May 2026)

The tribunal held that four disputed days were excluded under the statutory residence test, leaving the appellant with 89 UK days and non-resident for 2019/20.

  • Statutory residence test
  • Income tax
  • Exceptional circumstances exception
  • Transit exception
  • Tax residency
  • Statutory-residence-test
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Tax law [2022] UKFTT 112 (TC)

JONATHAN OPPENHEIMER v Revenue & Customs (INCOME TAX - whether resident in UK or RSA - Article 4 of the Republic of South Africa/UK Double Tax Treaty 2002)

JONATHAN OPPENHEIMER v Revenue & Customs (INCOME TAX - whether resident in UK or RSA - Article 4 of the Republic of South Africa/UK Double Tax Treaty 2002) [2022] UKFTT 112 (TC) (24 March 2022)

The Tribunal held that Jonathan Oppenheimer was treaty resident in South Africa, applying the UK/South Africa tax treaty tiebreakers on vital interests and habitual abode.

  • Double taxation
  • Tax residency
  • Treaty interpretation
  • Income tax
  • Habitual abode
  • Centre of vital interests
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Tax law [2022] UKFTT 112

JONATHAN OPPENHEIMER v Revenue & Customs (INCOME TAX - whether resident in UK or RSA - Article 4 of the Republic of South Africa/UK Double Tax Treaty 2002)

JONATHAN OPPENHEIMER v Revenue & Customs (INCOME TAX - whether resident in UK or RSA - Article 4 of the Republic of South Africa/UK Double Tax Treaty 2002) [2022] UKFTT 112 (TC) (24 March 2022)

The Tribunal allowed Jonathan Oppenheimer’s appeal, holding that his treaty residence under the UK/South Africa tax treaty was in South Africa.

  • Tax residency
  • Double tax treaties
  • Interpretation of treaties
  • Centre of vital interests
  • Habitual abode
  • Tie-breaker rules
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Tax law [2021] UKFTT 210

G E Financial Investments v Revenue & Customs (Corporation Tax - UK-US Double Tax Convention)

G E Financial Investments v Revenue & Customs (Corporation Tax - UK-US Double Tax Convention) [2021] UKFTT 210 (TC) (8 June 2021)

The tribunal held that share stapling under US tax law did not make GEFI a US resident for treaty purposes, and it also rejected the alternative permanent establishment claim.

  • Double taxation relief
  • Corporation tax
  • Tax residency
  • Permanent establishment
  • Uk-us double tax convention
  • Stapled entities
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Tax law [2021] UKFTT 210 (TC)

G E Financial Investments v Revenue & Customs (Corporation Tax - UK-US Double Tax Convention)

G E Financial Investments v Revenue & Customs (Corporation Tax - UK-US Double Tax Convention) [2021] UKFTT 210 (TC) (8 June 2021)

The Tribunal dismissed GEFI’s appeal, holding that a share-staple arrangement did not make it resident in the US under the treaty and that it had no US permanent establishment.

  • Corporation tax
  • Double taxation relief
  • Tax residency
  • Uk-us double tax convention
  • Corporation-tax
  • Double-taxation-relief
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Tax law [2013] UKFTT 637

Rumbelow & Anor v Revenue & Customs

Rumbelow & Anor v Revenue & Customs [2013] UKFTT 637 (TC) (31 October 2013)

The tribunal held that Mr and Mrs Rumbelow remained UK resident for the relevant tax years, finding no distinct break in the pattern of their lives after leaving the UK.

  • Capital gains tax
  • Tax residency
  • Self-assessment
  • Discovery assessments
  • Tax-residence
  • Capital-gains-tax
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Tax law [2013] UKFTT 637 (TC)

Rumbelow & Anor v Revenue & Customs

Rumbelow & Anor v Revenue & Customs [2013] UKFTT 637 (TC) (31 October 2013)

The Tribunal held that Mr and Mrs Rumbelow remained UK resident for the relevant tax years, finding no sufficient break in their UK ties after April 2001.

  • Capital gains tax
  • Tax residency
  • Self-assessment
  • Discovery assessments
  • Tax-residency
  • Capital-gains-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.