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United Kingdom Upper Tribunal (Tax and Chancery Chamber)


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2025 United Kingdom Upper Tribunal (Tax and Chancery Chamber)


You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> 2025 United Kingdom Upper Tribunal (Tax and Chancery Chamber)
URL: https://www.bailii.org/uk/cases/UKUT/TCC/

2025 United Kingdom Upper Tribunal (Tax and Chancery Chamber)

August 2024

  • Reynolds v The Financial Conduct Authority [2025] UKUT 123 (TCC) (06 August 2024)

December 2024

  • Assembly Global Networks Ltd v Revenue and Customs [2025] UKUT 23 (TCC) (16 December 2024)
  • Warner v Revenue and Customs [2025] UKUT 24 (TCC) (12 December 2024)

January

  • Bridgecom International Ltd v Revenue and Customs (PROCEDURE - COSTS - construction of Rule 11(2) Tribunal Procedure (FTT)(Tax Chamber) Rules 2009 requiring parties to send or deliver notice to Tribunal of appointment of non-legal representatives - application to costs shifting jurisdiction under Rule 10(1)(c) for cases allocated to the complex category) [2025] UKUT 3 (TCC) (07 January 2025)
  • Delaney v Revenue and Customs (Re Application for Permission to Appeal) [2025] UKUT 5 (TCC) (10 January 2025)
  • FS Commercial Ltd v Revenue and Customs (VAT - scope of grounds of appeal to the FTT - whether FTT jurisdiction supervisory or appellate) [2025] UKUT 13 (TCC) (14 January 2025)
  • Halstead v Revenue and Customs (Tax) [2025] UKUT 22 (TCC) (15 January 2025)
  • Hoopla Animation Ltd v Revenue and Customs [2025] UKUT 28 (TCC) (23 January 2025)
  • Laurence Supply Co (Leather Goods) Ltd v Revenue and Customs [2025] UKUT 31 (TCC) (28 January 2025)
  • Mahmood v Revenue and Customs [2025] UKUT 50 (TCC) (17 January 2025)
  • Revenue and Customs v Sonder Europe Ltd (VAT - Tour Operators' Margin Scheme - apartments leased to taxpayer and used to provide short term accommodation to travellers - whether supplies of designated travel service - whether any requirements that the bought-in supply be used for direct benefit of travellers) [2025] UKUT 14 (TCC) (14 January 2025)
  • Revenue and Customs v Yorkshire Agricultural Society (VALUE ADDED TAX - exemption for certain fund-raising events by charities - whether applicable to Great Yorkshire Show - meaning and application of Value Added Tax Act 1994 Schedule 9 Group 12 Item 1 - interpretation in conformity with Principal VAT Directive) [2025] UKUT 4 (TCC) (09 January 2025)
  • Teraiya v The Financial Conduct Authority (Financial Services) [2025] UKUT 34 (TCC) (31 January 2025)

February

  • Airedale Chemical Company Ltd, R (on the application of) v Revenue and Customs (JUDICIAL REVIEW - PROCEDURE - Claimants' application for disclosure) [2025] UKUT 65 (TCC) (24 February 2025)
  • Executors of Mrs Leslie Vivienne Elborne Deceased & Ors v Revenue and Customs [2025] UKUT 59 (TCC) (17 February 2025)
  • Rafferty v Revenue and Customs (INCOME TAX - discovery assessment and penalties for deliberate behaviour - adequacy of reasons given by First-tier Tribunal) [2025] UKUT 63 (TCC) (19 February 2025)
  • Singleton Birch Ltd & Anor v Revenue and Customs (LANDFILL TAX - section 42(2) Finance Act 1996 - Landfill Tax (Qualifying Material) Order 2011 - Note 9(a) - whether waste was entirely "calcium based reaction waste from titanium dioxide production" - whether FTT applied the right test) [2025] UKUT 72 (TCC) (28 February 2025)
  • Uflex Europe Ltd v Revenue and Customs (CUSTOMS DUTIES - importation of pet food bags using incorrect tariff classification code - submission by importer of requisite documentation outside applicable time limit - whether FTT erred in deciding that exception from time limit for a failure "due to exceptional circumstances" did not apply - whether arguments on appeal should be admitted) [2025] UKUT 57 (TCC) (14 February 2025)

March

  • Bunting v Revenue and Customs (CAPITAL GAINS TAX - entitlement to loss relief) [2025] UKUT 96 (TCC) (19 March 2025)
  • EAK Group 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...) [2025] UKUT 82 (TCC) (10 March 2025)
  • Fox-Bryant & Anor v The Financial Conduct Authority (FINANCIAL SERVICES - final decision on impact of taxation on, and appropriate rate of interest to be used in calculating, the amount to be disgorged in financial penalties) [2025] UKUT 87 (TCC) (12 March 2025)
  • Morgan Lloyd Trustees Ltd v Revenue and Customs (INCOME TAX - pensions - unauthorised payments - scheme sanction charges - contractual interpretation - what is meant by "the commercial context" - challenges to the FTT' findings of fact and evaluative judgments - time limit for making an application to be discharged from the scheme sanction charge) [2025] UKUT 102 (TCC) (25 March 2025)
  • Nellsar Ltd v Revenue and Customs (CORPORATION TAX - relief for amortisation of goodwill) [2025] UKUT 164 (TCC) (05 March 2025)
  • PD & MJ Ltd v Revenue and Customs (INCOME TAX - NATIONAL INSURANCE CONTRIBUTIONS - whether FTT erred in finding that under the hypothetical contracts...) [2025] UKUT 94 (TCC) (17 March 2025)
  • Revenue and Customs v Bolt Services UK Ltd (VALUE ADDED TAX - Tour Operators - Margin Scheme - mobile ride hailing services - whether services of a kind commonly provided by tour operators or travel agents - whether services materially altered or further processed) [2025] UKUT 100 (TCC) (24 March 2025)
  • Revenue and Customs v Canadian Solar EMEA GmbH (ANTI-DUMPING DUTY, COUNTERVAILING DUTY AND VAT - importation of solar panels made from cells originating in Taiwan) [2025] UKUT 142 (TCC) (12 March 2025)
  • St Patrick's International College Ltd & Ors v Revenue and Customs (VAT - exemption for supplies of education - Art.131(1)(i) Principal VAT Directive - whether properly implemented by Group 6 Schedule 9 VATA 1994 - whether definition of eligible body in Note (1) Group 6 breaches principle of fiscal neutrality - Item 5B Group 5 - whether consideration for courses supplied by two appellants to students who were eligible for student loans was ultimately a charge to funds provided by the Secretary of State - whether one appellant which was an eligible body pursuant to Note 1(f) by virtue of teaching English as a foreign language was entitled to exemption for all supplies of education) [2025] UKUT 101 (TCC) (24 March 2025)

April

  • George Mantides Ltd v Revenue and Customs (INCOME TAX AND NATIONAL INSURANCE CONTRIBUTIONS - IR35 - intermediaries legislation - FTT not entitled to make certain findings as to the terms of the hypothetical contract) [2025] UKUT 124 (TCC) (07 April 2025)
  • Joshi v Revenue and Customs (NATIONAL INSURANCE CONTRIBUTIONS - entitlement to State pension - late payment of voluntary contribution - date when entitlement to State pension commenced - appeal dismissed) [2025] UKUT 126 (TCC) (14 April 2025)

May

  • Butt & Anor v National Crime Agency (Income Tax - discovery assessments and penalties imposed by National Crime Agency ("NCA") adopting Revenue functions - whether FTT erred in not requiring NCA to meet a burden of showing loss of tax arising from trade of money laundering - effect of section 319 POCA 2005 - whether FTT entitled to find that there was a loss of tax - whether FTT entitled to find that the Second Appellant brought about a loss of tax deliberately) [2025] UKUT 145 (TCC) (09 May 2025)
  • Fox-Bryant & Anor v The Financial Conduct Authority (FINANCIAL SERVICES - final decision on the calculation of the amount to be disgorged in financial penalties) [2025] UKUT 152 (TCC) (13 May 2025)
  • Rettig Heating Group UK Ltd , R (on the application of) v Revenue and Customs (JUDICIAL REVIEW - HMRC's refusal to exercise discretion to extend time) [2025] UKUT 143 (TCC) (6 May 2025)
  • Scatola & Ors v Revenue and Customs (STAMP DUTY LAND TAX - procedural requirements under Schedule 10, Finance Act 2003 where ineffective avoidance arrangements caught by s.75A - Enquiry Appeal - validity of notices of enquiry - understanding of reasonable recipient - Assessment Appeal - validity of discovery assessments made under extended time limit in paragraph 31(2A)(b) - whether Appellants failed to file a return in respect of the notional transaction pursuant to s75A) [2025] UKUT 156 (TCC) (25 May 2025)
  • Walkers Snack Foods Ltd v Revenue and Customs (Value Added Tax - excepted item 5 to item 1, Group 1, Part II, Schedule 8 Value Added Tax Act 1994 - whether First-tier Tribunal erred in law in finding Sensations Poppadoms were "made from the potato, or from potato flour, or from potato starch" and were "similar" to potato crisps) [2025] UKUT 155 (TCC) (22 May 2025)

June

  • Banque Havilland SA & Ors v The Financial Conduct Authority (FINANCIAL SERVICES - procedure - application for a witness summons) [2025] UKUT 197 (TCC) (24 June 2025)
  • DHL Air (UK) Ltd v Revenue and Customs (CUSTOMS DUTIES - Union Customs Code - importation of civil aircraft) [2025] UKUT 176 (TCC) (06 June 2025)
  • Donaldson & Anor v The Financial Conduct Authority (FINANCIAL SERVICES - Metro Bank's trading update for Q3 2018 included incorrect statements about risk - meaning of "knowingly concerned") [2025] UKUT 185 (TCC) (16 June 2025)
  • JPMorgan Chase Bank NA v Revenue and Customs (VAT - Intra-group provision of services by infrastructure providing entity within group - issue arising over whether supply or supplies taxable) [2025] UKUT 188 (TCC) (17 June 2025)
  • Murphy v Revenue and Customs [2025] UKUT 165 (TCC) (03 June 2025)
  • Osmond & Anor v Revenue and Customs (INCOME TAX - transactions in securities - share buyback - shares benefitting from EIS CGT disposal relief - main purpose to obtain CGT relief - was there necessarily a main purpose to obtain an income tax advantage) [2025] UKUT 183 (TCC) (13 June 2025)
  • Staley v Financial Conduct Authority [2025] UKUT 203 (TCC) (26 June 2025)

Other cases from 2025

  • <title>Queenscourt Limited v Revenue and Customs [2025] UKUT 84 (TCC) (11 March 2025)</title>


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