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United Kingdom Upper Tribunal (Tax and Chancery Chamber)


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2024 United Kingdom Upper Tribunal (Tax and Chancery Chamber)


You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> 2024 United Kingdom Upper Tribunal (Tax and Chancery Chamber)
URL: https://www.bailii.org/uk/cases/UKUT/TCC/

2024 United Kingdom Upper Tribunal (Tax and Chancery Chamber)

January

  • Commissioners for His Majesty's Revenue and Customs v Applicants in the Post Prudential Closure Notice Applications Group Litigation & Anor (Corporation tax - double taxation relief on foreign dividend income - portfolio holdings - procedural issues arising out of claims for relief and claims for repayment of overpaid tax following the UK's established breach of EU law) [2024] UKUT 23 (TCC) (25 January 2024)
  • Commissioners for His Majesty's Revenue and Customs v Hippodrome Casino Ltd (VAT - recovery of residual input tax - whether FtT erred in failing to determine whether there was a dual use of taxable supplies of entertainment and hospitality also for the non-taxable supplies of gaming in the casino) [2024] UKUT 27 (TCC) (29 January 2024)
  • Commissioners for His Majesty's Revenue and Customs v The Taxpayer (INCOME TAX - Penalty under s208 Finance Act 2014 issued after issue of follower notice in relation to arrangements said to give rise to loss on 'relevant discounted securities' (Schedule 13 Finance Act 1996) - whether FTT erred in its approach to holding judicial ruling (Audley v HMRC) was 'relevant' to taxpayer's arrangements because it had regard to 'post-Ramsey analysis' facts rather than primary facts) [2024] UKUT 21 (TCC) (22 January 2024)
  • Exchequer Solutions Ltd v Commissioners for His Majesty's Revenue and Customs (PAYE & NIC - travel and subsistence expenses paid by umbrella company servicing construction industry clients - whether mutuality of obligation to constitute overarching contract of employment or whether arrangement amounted to series of individual assignments in which case travel expenses not allowable as ordinary commuting expenses) [2024] UKUT 25 (TCC) (24 January 2024)

February

  • Hartleb T/A Hartleb Transport v Commissioners for His Majesty's Revenue and Customs (EXCISE DUTIES - Reg. 13(2)(b) of the Excise Goods (Holding, Movement and Duty Point) Regulations 2010) [2024] UKUT 34 (TCC) (01 February 2024)
  • MATHUR v Revenue and Customs [2024] UKUT 38 (TCC) (12 February 2024)
  • Nvayo Ltd v The Financial Conduct Authority (FINANCIAL SERVICES - procedure - supervisory notices imposing requirements taking immediate effect in relation to e-money institution's new and existing business and its assets) [2024] UKUT 35 (TCC) (05 February 2024)
  • Revenue and Customs v RIDGWAY [2024] UKUT 36 (TCC) (9 February 2024)
  • Thyssenkrupp Materials (UK) Ltd v Commissioners for His Majesty's Revenue and Customs (CUSTOMS DUTY - inward processing relief - requirements of a bill of discharge (BoD) - whether a single error or data mismatch between BoD and HMRC's Management Support System gives rise to a customs debt under Art. 204 Community Customs Code in relation to all products on the BoD) [2024] UKUT 79 (TCC) (28 February 2024)

March

  • Beard v Revenue and Custom (Distributions from share premium - Jersey law - whether the distributions were "dividends" - and whether the distributions were "dividends of a capital nature") [2024] UKUT 73 (TCC) (22 March 2024)
  • Coconut Animated Island Ltd v Revenue and Customs (SEED ENTERPRISE INVESTMENT SCHEME) [2024] UKUT 75 (TCC) (25 March 2024)
  • Executors of the Estate of Peter John Linington & Anor v Commissioners for His Majesty's Revenue and Customs (Protective costs order - Approach in Drummond v HM Revenue & Customs followed) [2024] UKUT 70 (TCC) (19 March 2024)
  • Haworth & Ors v Revenue and Customs (Capital gains tax - treaty relief pursuant to the UK/Mauritius double taxation treaty) [2024] UKUT 58 (TCC) (04 March 2024)
  • Sehgal & Anor v Revenue and Customs (Remittance of foreign gains - indemnity liability waived and UK inter-company debt not pursued pursuant to payment by non-UK third party overseas in separate transaction financed by taxpayers using proceeds of offshore chargeable gains) [2024] UKUT 74 (TCC) (25 March 2024)
  • WTGIL Ltd v Commissioners for His Majesty's Revenue and Customs (VALUE ADDED TAX - whether supply and fitting of 'black box' device to cars as condition of insurance policy was a supply of goods or services for consideration to holders of insurance policies - whether supply was deemed a supply of goods) [2024] UKUT 77 (TCC) (26 March 2024)

April

  • AD Bly Groundworks and Civil Engineering Ltd & Anor v Revenue and Customs (CORPORATION TAX - whether provisions in company's accounts in respect of liabilities to make future pension payments were deductible expenses incurred wholly and exclusively for the purposes of a trade) [2024] UKUT 104 (TCC) (22 April 2024)
  • Commissioners for His Majesty's Revenue and Customs v Innovative Bites Ltd (Value Added Tax, Zero-Rating, Food, Confectionery, Note 5 Item 2 of Group 1 Schedule 8 Value Added Tax Act 1994 - Multi-Factorial Assessment when considering Note 5 - Whether FTT erred in concluding Mega Marshmallows are not confectionery) [2024] UKUT 95 (TCC) (04 April 2024)
  • Commissioners for His Majesty's Revenue and Customs v Marlborough DP Ltd (INCOME TAX - tax avoidance scheme - whether amounts paid by respondent under trust arrangements taxable as earnings from employment under s62 ITEPA 2003 - whether taxable as earnings under Part 7A ITEPA 2003 because paid "in connection with" employment - Edwards v Bairstow challenge) [2024] UKUT 98 (TCC) (12 April 2024)
  • Cozy Pet Ltd v Revenue and Customs (CUSTOMS DUTIES - combined nomenclature) [2024] UKUT 96 (TCC) (08 April 2024)
  • Hughes & Anor v Revenue and Customs (EXCISE DUTY - assessment in respect of duty unpaid cigarettes) [2024] UKUT 108 (TCC) (29 April 2024)
  • McCann Media Ltd v Commissioners for His Majesty's Revenue and Customs (Income Tax, PAYE, National Insurance Constributions, whether sec.49(1)(c)(i) ITEPA and Regulation 6(1)(c) Social Security Contributions (Intermediaries) Regulations 2000 (SI 2000/727) apply) [2024] UKUT 94 (TCC) (05 April 2024)
  • Qubic Advisory Services Ltd v Commissioners for His Majesty's Revenue and Customs (Value Added Tax - supplies of gold - whether record keeping requirements of s.6.4 and s.7.1 of VAT Notice 701/21 (Gold Imports & Exports) apply) [2024] UKUT 106 (TCC) (23 April 2024)
  • Revenue And Customs v Marlborough DP Limited [2024] UKUT 103 (TCC) (16 April 2024)
  • Revenue And Customs v RALC Consulting Ltd (INCOME TAX - NATIONAL INSURANCE CONTRIBUTIONS - intermediaries legislation) [2024] UKUT 99 (TCC) (12 April 2024)

May

  • Banque Havilland SA & Ors v The Financial Conduct Authority [2024] UKUT 115 (TCC) (8 May 2024)
  • Commissioners of His Majesty's Revenue and Customs v Hitchins & Ors (Income tax - application for closure notices - whether reasonable for HMRC to continue with their enquiries - FTT directed a closure notice under s.28A Taxes Management Act 1970) [2024] UKUT 114 (TCC) (08 May 2024)
  • Nottingham Forest Football Club Ltd v Revenue and Customs (Procedure - Value Added Tax) [2024] UKUT 145 (TCC) (22 May 2024)
  • Revenue & Customs v Burlington Loan Management DAC (UK-Ireland double tax convention) [2024] UKUT 152 (TCC) (31 May 2024)
  • Silverdoor Ltd v Revenue And Customs [2024] UKUT 147 (TCC) (23 May 2024)
  • Tenconi v Revenue And Customs (CAPTAL GAINS TAX – whether FTT erred in concluding taxpayer's transfer of the beneficial interest in distribution rights in company) [2024] UKUT 110 (TCC) (01 May 2024)

June

  • Ali v Commissioners for His Majesty's Revenue and Customs (EXCISE DUTY - assessment in respect of duty unpaid tobacco) [2024] UKUT 176 (TCC) (18 June 2024)
  • Baxendale-Walker v Revenue and Customs [2024] UKUT 154 (TCC) (03 June 2024)
  • Burdett & Anor v The Financial Conduct Authority [2024] UKUT 156 (TCC) (04 June 2024)
  • Carvajal & Anor v Revenue and Customs (INHERITANCE TAX - whether a guarantee executed by a person (the "settlor")) [2024] UKFTT 651 (TC) (11 June 2024)
  • Revenue And Customs v Basic Broadcasting Ltd [2024] UKUT 165 (TCC) (7 June 2024)
  • Spectrum Community Health CIC v Commissioners for His Majesty's Revenue and Customs (VAT - exemption - Article 132(1)(b) VAT directive - provision of healthcare in prisons) [2024] UKUT 162 (TCC) (06 June 2024)
  • Telent Technology Services Ltd v Revenue And Customs (withdrawal of an appeal to the FTT against a VAT assessment recovering input tax credit) [2024] UKUT 183 (TCC) (20 June 2024)
  • Ulster Metal Refiners Ltd v Commissioners for His Majesty's Revenue and Customs (COSTS - whether a clear winner before the FTT - costs awarded but reduced to take into account conduct & other factors) [2024] UKUT 184 (TCC) (25 June 2024)
  • Watts v Revenue and Customs (TAX AVOIDANCE - INCOME TAX - loss determination on disposal of gilt strips) [2024] UKUT 168 (TCC) (12 June 2024)

July

  • Barclays Plc & Anor v The Financial Conduct Authority (FINANCIAL SERVICES - procedure - application for a witness summons) [2024] UKUT 214 (TCC) (24 July 2024)
  • Makvicius v Revenue and Customs [2024] UKUT 321 (TCC) (22 July 2024)
  • Outram & Anor v Revenue And Customs (INCOME TAX - discovery assessments) [2024] UKUT 203 (TCC) (15 July 2024)
  • Revenue and Customs v Suterwalla & Anor (Stamp Duty Land Tax - whether mixed residential and non-residential use) [2024] UKUT 188 (TCC) (01 July 2024)

August

  • Commissioners for His Majesty's Revenue and Customs v S & L Barnes Ltd (INCOME TAX AND NATIONAL INSURANCE - intermediaries legislation - IR35 - personal service company - finding by FTT that a contractual right of first call would be varied in the hypothetical contract - application of and approach to the third stage of the RMC test of employment) [2024] UKUT 262 (TCC) (28 August 2024)
  • Cranham Sports LLP v Commissioners for His Majesty's Revenue and Customs (LATE APPEAL - whether FTT's decision wrongly premised on lateness of appeal being due solely due to a mistake - HMRC's failure to disclose material - inability of the appellant to consider properly an appeal or review in the absence of material not disclosed by HMRC) [2024] UKUT 209 (TCC) (01 August 2024)
  • Mainpay Ltd v Revenue And Customs (INCOME TAX - umbrella company engaging temporary workers) [2024] UKUT 233 (TCC) (16 August 2024)
  • Promethean Finance Ltd v The Financial Conduct Authority (FINANCIAL SERVICES - registration of non-genuine trading names as trading names of the Applicant on the Financial Services Register) (Rev2) [2024] UKUT 229 (TCC) (05 August 2024)
  • Saranac Partners Ltd v Financial Conduct Authority (FINANCIAL SERVICES) [2024] UKUT 254 (TCC) (24 August 2024)
  • Spirit Motor Company Ltd v Revenue and Customs [2024] UKUT 230 (TCC) (05 August 2024)
  • UBS AG, R (on the application of) v Revenue and Customs (JUDICIAL REVIEW - challenge to HMRC's refusal to exercise discretion to remove obligation on employer to account for PAYE in respect of employee's tax liability on earnings in the form of gilts) [2024] UKUT 242 (TCC) (21 August 2024)
  • Wired Orthodontics Ltd & Ors v Revenue and Customs [2024] UKUT 266 (TCC) (29 August 2024)

September

  • Ashraf Wealth Management Ltd v The Financial Conduct Authority (FINANCIAL SERVICES - decision by the Authority not to authorise the Applicant to carry out regulated activities on the basis that the Applicant would not satisfy and continue to satisfy the threshold conditions...) [2024] UKUT 265 (TCC) (02 September 2024)
  • Bandstream Media and Corporate Communications Ltd v Revenue and Customs (TAX) [2024] UKUT 306 (TCC) (26 September 2024)
  • Commissioners for His Majesty's Revenue and Customs v Zaman (PERSONAL LIABILITY NOTICE - whether FTT's decision contains error of law on Edwards v Bairstow grounds) [2024] UKUT 278 (TCC) (11 September 2024)
  • McCabe v Commissioners for His Majesty's Revenue and Customs (Residence - whether Appellant had ceased to be UK resident - application of case law test and application of UK/Belgium DTC - application of COVI limb of DTC tie-breaker) [2024] UKUT 280 (TCC) (12 September 2024)
  • Muller UK and Ireland Group LLP & Ors v Revenue and Customs [2024] UKUT 273 (TCC) (06 September 2024)
  • Revenue And Customs v Gould (TAX) [2024] UKUT 285 (TCC) (17 September 2024)
  • TalkTalk Telecom Ltd v Commissioners for His Majesty's Revenue and Customs (Value Added Tax - para 4 Schedule 6 VAT Act 1994 - whether services supplied on terms allowing a discount for prompt payment) [2024] UKUT 284 (TCC) (12 September 2024)

October

  • Fluid Systems Technologies (Scotland) Ltd & Ors, R (on the application of) v Revenue and Customs (UDICIAL REVIEW - PROCEDURE - Claimants' application for cross-examination of a witness) [2024] UKUT 322 (TCC) (09 October 2024)
  • Kay v Revenue and Customs (permission to appeal) [2024] UKUT 350 (TCC) (21 October 2024)
  • Midlands Partnership University NHS Foundation Trust, R (on the application of) v Revenue and Customs (HMRC decision that NHS foundation trust not entitled to refund of COS ("Contracted Out Services")) [2024] UKUT 334 (TCC) (25 October 2024)
  • Mudan & Anor v Commissioners for His Majesty's Revenue and Customs (STAMP DUTY LAND TAX - building previously used as dwelling in need of renovation and repair at time of completion of purchase - whether building 'suitable for use as a single dwelling') [2024] UKUT 307 (TCC) (01 October 2024)
  • Rettig Heating Group UK Ltd, R (on the application of) v Revenue and Customs [2024] UKUT 315 (TCC) (07 October 2024)
  • Trustees of the Panico Panayi Accumulation and Maintenance Settlements Numbers 1 to 4 & Anor v Commissioners for His Majesty's Revenue and Customs (CHARGEABLE GAINS - deemed disposal on ceasing to be resident in UK and becoming resident in another EU member state - compatibility with EU freedoms - ss80 and 185 TCGA, para 10A, Sch 9, FA 96, and ss59B and 59D TMA) [2024] UKUT 319 (TCC) (08 October 2024)

November

  • ARIAN FINANCIAL LLP v THE FINANCIAL CONDUCT AUTHORITY [2024] UKUT 352 (TCC) (11 November 2024)
  • Beigebell Ltd (No. 2) v Commissioners for His Majesty's Revenue and Customs (VAT - MTIC appeal - whether FTT erred on burden of proof - Edwards v Bairstow challenge to findings of fact) [2024] UKUT 382 (TCC) (26 November 2024)
  • Darren Anthony Wilson v The Charity Commission for England and Wales [2024] UKUT 347 (TCC) (7 November 2024)
  • DAVID BRIAN PRICE and TONI FOX-BRYANT v THE FINANCIAL CONDUCT AUTHORITY [2024] UKUT 357 (TCC) (13 November 2024)
  • Eveleigh v Revenue and Customs (PROCEDURE - Application to extend time to file notice of appeal outside of one month time limit - three stage approach in Martland applied) [2024] UKUT 435 (TCC) (20 November 2024)
  • Newfield v Revenue and Customs (permission to appeal) [2024] UKUT 385 (TCC) (27 November 2024)
  • Revenue and Customs v Sintra Global, Inc & Anor (VAT - EXCISE DUTIES - burden of proof in penalty cases where taxpayer challenges the assessment to tax) [2024] UKUT 346 (TCC) (07 November 2024)
  • The Tower One St George Wharf Limited v Revenue and Customs (STAMP DUTY LAND TAX - group relief - arrangements of which one of the main purposes is the avoidance of liability to tax) [2024] UKUT 373 (TCC) (20 November 2024)

December

  • B&M Retail Ltd v Revenue and Customs (EXCISE DUTY - penalty issued - whether appellant had reasonable excuse) [2024] UKUT 409 (TCC) (10 December 2024)
  • Commissioners for His Majesty's Revenue and Customs v Colchester Institute Corporation (VAT - whether provision of free educational/vocational training to students where funding provided by government agencies was supply of services for consideration) [2024] UKUT 397 (TCC) (04 December 2024)
  • Digital Buying Partners Ltd v Revenue and Customs [2024] UKUT 437 (TCC) (23 December 2024)
  • Dunne v Financial Conduct Authority (FINANCIAL SERVICES - PRIVACY APPLICATIONS - Section 391 FSMA - Rule 14 and Para 3, Schedule 3 to the Tribunal Procedure (Upper Tribunal) Rules 2008 - effect of publication of Decision Notice and details of reference on the register on the Applicant's mental health) (Rev1) [2024] UKUT 416 (TCC) (11 December 2024)
  • Hague v Revenue and Customs [2024] UKUT 436 (TCC) (20 December 2024)
  • M R Currell Ltd v Revenue And Customs (INCOME TAX AND NICs - PAYE - payment to an EBT, loan of same amount to a director) [2024] UKUT 404 (TCC) (06 December 2024)
  • New Claire Wine Ltd v Commissioners for His Majesty's Revenue and Customs (Reconsideration of Application for Permission to Appeal) [2024] UKUT 390 (TCC) (02 December 2024)
  • Revenue and Customs v Dettori (Anonymisation) [2024] UKUT 364 (TCC) (09 December 2024)
  • Revenue And Customs v Dettori [2024] UKUT 12 (TCC) (09 December 2024)
  • Staley v Financial Conduct Authority (FINANCIAL SERVICES - procedure - whether Tribunal should direct evidence from further witnesses - whether Applicant should be permitted to give evidence in chief orally - whether Authority sould have permission to amend Statement of Case - whether Authority should be directed to disclose further documents) [2024] UKUT 394 (TCC) (03 December 2024)


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