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HC-ONE No. 1 Ltd v Revenue and Customs (Stamp Duty Land Tax) (Rev1) [2026] UKFTT 678 (TC) (08 May 2026)
The tribunal held that group relief for intra-group SDLT transfers was preserved because the liquidation fell within paragraph 4(4), and section 75A did not apply.
HC-ONE No. 1 Ltd v Revenue and Customs (Stamp Duty Land Tax) (Rev1) [2026] UKFTT 678 (TC) (08 May 2026)
The tribunal held that group relief for intra-group SDLT transfers was available, the liquidation exception applied, and section 75A did not recharacterise the sale.
Fleet v Revenue and Customs (INCOME TAX - claim for charitable giving relief - whether evidence of gift made by taxpayer - whether charity met the test of the Income Tax Act 2007 - whether tax return contained careless inaccuracies resulting in an understatement of liability to tax - whether penalty was due and finally calculated correctly - Sections 431 and 989 Income Tax Act 2007 and Schedule 24 Finance Act 2007) [2026] UKFTT 507 (TC) (31 March 2026)
The tribunal dismissed Simon Fleet’s appeal, finding insufficient evidence of a qualifying gift of shares to a charity and upholding HMRC’s penalty for carelessness.
King v Revenue and Customs (INCOME TAX - loan contractor scheme - validity of discovery assessments - s29(5) TMA) [2026] UKFTT 394 (TC) (13 March 2026)
The First-tier Tribunal upheld HMRC discovery assessments against a contractor loan scheme user, finding s29(5) TMA was satisfied for all relevant years.
King v Revenue and Customs (INCOME TAX - loan contractor scheme - validity of discovery assessments - s29(5) TMA) [2026] UKFTT 394 (TC) (13 March 2026)
The First-tier Tribunal dismissed Jonathan King’s appeal, upholding HMRC discovery assessments arising from a contractor loan scheme under s29 TMA.
Foster v The Information Commissioner & Anor [2025] UKFTT 1237 (GRC) (20 October 2025)
The tribunal dismissed a FOIA appeal about HMRC’s use of the Serial Tax Avoiders Regime, holding that section 31(1)(d) applied and the public interest favoured non-disclosure.
Burley v Revenue and Customs (INCOME TAX - purported assignment of interests in partnership profits - whether purported assignor remained entitled to those profits) [2025] UKFTT 989 (TC) (14 August 2025)
The Tribunal dismissed Mr Burley’s appeal, holding that he remained entitled to partnership profits for income tax purposes despite an alleged equitable assignment to an LLP.
Eastern Power Networks PLC & Ors v Revenue and Customs (CORPORATION TAX - consortium relief - Issue 1 concerned the ownership proportions...) [2025] UKFTT 703 (TC) (10 June 2025)
The Tribunal held that consortium relief ownership proportions had to be calculated collectively across linked companies, and that s146B applied. The appeal was dismissed.
Eastern Power Networks PLC & Ors v Revenue and Customs (CORPORATION TAX - consortium relief - Issue 1 concerned the ownership proportions...) [2025] UKFTT 703 (TC) (10 June 2025)
The Tribunal dismissed a consortium relief appeal, holding that multiple link companies must be read collectively for ownership proportions and that s146B applied.
Hive Umbrella Ltd v Revenue and Customs (DISCLOSURE OF TAX AVOIDANCE SCHEMES (DOTAS) - Whether the arrangements were notifiable arrangements) [2025] UKFTT 457 (TC) (17 April 2025)
The Tribunal dismissed Hive Umbrella Ltd’s appeal, holding its bonus-and-advance arrangements were notifiable under DOTAS and that Hive was a promoter.
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