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Tax law [2026] UKFTT 627

Thomas v Revenue and Customs (Taxation of shareholder on assignment of debt - whether deliberate - whether there has been a discovery...)

Thomas v Revenue and Customs (Taxation of shareholder on assignment of debt - whether deliberate - whether there has been a discovery...) [2026] UKFTT 627 (TC) (24 April 2026)

The Tribunal held that a company debt assignment to the appellant was a taxable distribution to the extent it exceeded her loan account, and upheld a reduced penalty.

  • Taxation of shareholder on assignment of debt
  • Income tax on distributions
  • Discovery assessment
  • Penalties for deliberate behaviour
  • Section 54 taxes management act agreements
  • Article 6 echr in tax penalties
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Tax law [2026] UKFTT 627 (TC)

Thomas v Revenue and Customs (Taxation of shareholder on assignment of debt - whether deliberate - whether there has been a discovery...)

Thomas v Revenue and Customs (Taxation of shareholder on assignment of debt - whether deliberate - whether there has been a discovery...) [2026] UKFTT 627 (TC) (24 April 2026)

The Tribunal held that a debt assignment to the Appellant was taxable as a distribution to the extent it exceeded her loan account, and upheld the penalty, varied to the correct amount.

  • Taxation of shareholder on assignment of debt
  • Income tax on distributions
  • Discovery assessment
  • Penalties for deliberate behaviour
  • Section 54 taxes management act agreements
  • Article 6 echr in tax penalties
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Tax law [2026] UKFTT 615

Madsen v Revenue and Customs (SDLT avoidance; grant of call option prior to completion; Finance Act 2003, s.45 (as it stood in 2011); discovery assessment; knowledge of hypothetical officer)

Madsen v Revenue and Customs (SDLT avoidance; grant of call option prior to completion; Finance Act 2003, s.45 (as it stood in 2011); discovery assessment; knowledge of hypothetical officer) [2026] UKFTT 615 (TC) (21 April 2026)

The Tribunal allowed an SDLT appeal, holding that a 31 January 2012 disclosure letter was received and gave HMRC enough information to bar a discovery assessment.

  • Stamp duty land tax (sdlt)
  • Discovery assessment
  • Disclosure requirements
  • Finance act 2003
  • Sdlt avoidance schemes
  • Stamp-duty-land-tax
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Tax law [2026] UKFTT 615 (TC)

Madsen v Revenue and Customs (SDLT avoidance; grant of call option prior to completion; Finance Act 2003, s.45 (as it stood in 2011); discovery assessment; knowledge of hypothetical officer)

Madsen v Revenue and Customs (SDLT avoidance; grant of call option prior to completion; Finance Act 2003, s.45 (as it stood in 2011); discovery assessment; knowledge of hypothetical officer) [2026] UKFTT 615 (TC) (21 April 2026)

The Tribunal allowed an SDLT appeal, holding that a 31 January 2012 disclosure letter, together with the return, meant the discovery assessment was invalid.

  • Stamp duty land tax (sdlt)
  • Discovery assessment
  • Disclosure requirements
  • Finance act 2003
  • Tax avoidance schemes
  • Stamp-duty-land-tax
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Tax law [2026] UKFTT 583 (TC)

Boulton v Revenue and Customs (INCOME TAX validity of discovery assessment and penalty - whether a settlement agreement with liquidator constituted a release or write-off of director's loan - whether return contained a carelessness inaccuracy)

Boulton v Revenue and Customs (INCOME TAX validity of discovery assessment and penalty - whether a settlement agreement with liquidator constituted a release or write-off of director's loan - whether return contained a carelessness inaccuracy) [2026] UKFTT 583 (TC) (15 April 2026)

The Tribunal upheld an income tax discovery assessment and penalty, finding a liquidator settlement and letter amounted to a write-off of a director’s loan.

  • Discovery assessment
  • Director's loan account
  • Release or write-off
  • Careless inaccuracy
  • Penalty for errors
  • Discovery-assessment
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Tax law [2026] UKFTT 583

Boulton v Revenue and Customs (INCOME TAX validity of discovery assessment and penalty - whether a settlement agreement with liquidator constituted a release or write-off of director's loan - whether return contained a carelessness inaccuracy)

Boulton v Revenue and Customs (INCOME TAX validity of discovery assessment and penalty - whether a settlement agreement with liquidator constituted a release or write-off of director's loan - whether return contained a carelessness inaccuracy) [2026] UKFTT 583 (TC) (15 April 2026)

The Tribunal upheld a discovery assessment and Schedule 24 penalty over an omitted director’s loan write-off, finding the settlement and letter amounted to a release or write-off.

  • Discovery assessment
  • Director's loan account
  • Release or write-off
  • Careless inaccuracy
  • Penalty for errors
  • Discovery-assessment
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Tax law [2026] UKFTT 231 (TC)

Uzoh v Revenue and Customs (Discovery assessment - s29(4) TMA - s336, s337 and s338 ITEPA)

Uzoh v Revenue and Customs (Discovery assessment - s29(4) TMA - s336, s337 and s338 ITEPA) [2026] UKFTT 231 (TC) (05 February 2026)

The tribunal upheld HMRC discovery assessments for employment expenses claimed as ordinary commuting, finding the claims unsupported and the appellant careless.

  • Discovery assessment
  • Employment expenses
  • Self-assessment
  • Carelessness
  • Ordinary commuting
  • Temporary workplace
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Tax law [2026] UKFTT 231

Uzoh v Revenue and Customs (Discovery assessment - s29(4) TMA - s336, s337 and s338 ITEPA)

Uzoh v Revenue and Customs (Discovery assessment - s29(4) TMA - s336, s337 and s338 ITEPA) [2026] UKFTT 231 (TC) (05 February 2026)

The tribunal dismissed an appeal against four discovery assessments for employment expense claims, finding the expenses were not allowable and the appellant had been careless.

  • Discovery assessment
  • Income tax
  • Employment expenses
  • Carelessness
  • Self-assessment
  • Statutory appeal rights
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Tax law [2026] UKFTT 158 (TC)

Odina v Revenue and Customs (HICBC - Discovery Assessment - adjusted net income in excess of £50,000 - inclusion of entitlement to share of rental income on properties co-owned with her then husband)

Odina v Revenue and Customs (HICBC - Discovery Assessment - adjusted net income in excess of £50,000 - inclusion of entitlement to share of rental income on properties co-owned with her then husband) [2026] UKFTT 158 (TC) (28 January 2026)

The First-tier Tribunal upheld discovery assessments for HICBC on jointly owned rental income, finding the appellant was beneficially entitled to half the income and had not shown the assessments were wrong.

  • Higher income child benefit charge
  • Discovery assessment
  • Adjusted net income
  • Joint property income
  • Beneficial entitlement
  • Higher-income-child-benefit-charge
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Tax law [2026] UKFTT 158

Odina v Revenue and Customs (HICBC - Discovery Assessment - adjusted net income in excess of £50,000 - inclusion of entitlement to share of rental income on properties co-owned with her then husband)

Odina v Revenue and Customs (HICBC - Discovery Assessment - adjusted net income in excess of £50,000 - inclusion of entitlement to share of rental income on properties co-owned with her then husband) [2026] UKFTT 158 (TC) (28 January 2026)

The tribunal upheld HICBC discovery assessments against the appellant, finding her jointly owned rental income was taxable in equal shares and no valid Form 17 had been filed.

  • Higher income child benefit charge
  • Discovery assessment
  • Adjusted net income
  • Joint property income
  • Beneficial entitlement
  • Self-assessment returns
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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.

Source links and collection timestamps are retained alongside the indexed records.