IntroductionIn Boulting v Revenue and Customs Commissioners [2025] UKFTT 1272 (TC), the First-tier Tribunal considered whether proceeds from a company’s purchase of its own shares should be treated as an income distribution or as a capital disposal subject to capital gains tax. The decision provides helpful clarification on how the “benefit of the trade” test […]
In T Masters v HMRC [2025] UKFTT 967 (TC) (11 August), the First-tier Tribunal concluded that pension withdrawals taken from a self-invested personal pension (SIPP) by an individual living in Portugal were outside the scope of UK taxation. The Tribunal decided that the link to Mr Masters’ past employment remained intact despite the transfer of […]
The Court of Appeal has reaffirmed HMRC’s longstanding approach to the place of effective management (POEM) of trusts in the context of pre-2006 “round-the-world” tax avoidance schemes. In Haworth v HMRC [2025] EWCA Civ 845, the Court held that the POEM of a trust that had briefly appointed Mauritian trustees was, in substance, in the […]
In a decision with important implications for property investors and developers, the Court of Appeal has upheld HMRC’s interpretation of “residential property” for Stamp Duty Land Tax (SDLT) purposes, confirming that substantial renovation needs do not necessarily disqualify a property from being treated as residential. In Mudan v HMRC [2025] EWCA Civ 799, the taxpayers […]
In a significant decision for non-domiciled individuals claiming Business Investment Relief (BIR), the Upper Tribunal has confirmed that any extraction of value from a company in which a qualifying investment has been made may trigger a clawback of relief, even if there is no net benefit to the investor. In D’Angelin v Revenue and Customs […]
