The Disappointment of Winning

Our firm recently won a case at the Tribunal or, to use the more formal language of the Courts, the Tribunal decided a case in favour of our client. You would think that we would be celebrating – but we...

When an appeal becomes unappealing

When a UK taxpayer receives an Assessment or Determination or Penalty Notice from HMRC, typically their adviser will encourage them to appeal on the grounds that “You’ve got nothing to lose by appealing”. Unfortunately, in some instances, that can be...

The Value of the Independent Internal Review – COS Systems v HMRC

Back in the early 2000’s, HMRC was becoming concerned at the number of appeal cases being listed for hearing by what was then the General and Special Commissioners and, after consideration and consultation, in 2009 they introduced a new system...

Mr Tooth Bites Back

The Taxes legislation has long reserved the heaviest penalties for the taxpayer with the most heinous behaviour – so that there is a heavier penalty for the taxpayer who deliberately evades his tax than there would be if he got...

HMRC fail to delay hearing in Degorce to align proceedings with another year’s appeal

Patrick Degorce has invested in film schemes in 2006/07 and 2007/08. His appeal against HMRC’s refusal of relief for 2006/07 was turned down by the Upper Tribunal ([2015]UKUT447) in September 2015 but he has appealed against that decision and the case...

Spurs spared NIC and £30k exemption applies to compensation to transferred players

The First-tier Tribunal (FtT) has ruled that payments made by Tottenham Hotspur (Spurs) to Peter Crouch and Wilson Palacios to obtain their reluctant agreement to be transferred as part of a cost-cutting exercise were not sums that arose from their...