A Significant Ruling on the Interpretation of Exceptional Circumstances In A Taxpayer v Revenue and Customs Commissioners [2025] EWCA Civ 106, the Court of Appeal has provided key clarification on the interpretation of “exceptional circumstances” under the Statutory Residence Test (SRT). The ruling overturns the Upper Tribunal's (UT) restrictive approach and restores the original decision […]
Today, Rachel Reeves, the UK Chancellor has delivered the first Labour's Budget in 14 years. The Chancellor had widely anticipated that this would have involved making "difficult decisions” with tax rises and spending cuts in the value of £40bn. However, the Office for Budget Responsibility has published a detailed assessment of Labour's policies for the next […]
In GCH Corp Ltd v Revenue and Customs Commissioners, the tribunal assessed whether GCH Corp’s LLP was "carrying on a business with a view to profit" as required under Section 59A(1) of the Taxation of Chargeable Gains Act 1992 (TCGA). This decision was pivotal in determining if the LLP could be treated as tax-transparent, which […]
On 14 October 2024, the Independent Expert Panel, which was convened in December 2023 to guide the government on establishing a corporate re-domiciliation framework in the UK, published its much-anticipated report. This follows the UK government's initial consultation on introducing a corporate re-domiciliation regime in October 2021. Key Recommendations from the Report: The UK government […]
In a recent Upper Tribunal case, Amarjeet Mudan and Tajinder Mudan vs HMRC [2024] UKUT 00307 (TCC), the critical issue of whether a building is "suitable for use as a dwelling" was at the heart of the dispute regarding Stamp Duty Land Tax (SDLT). The case revolved around the Mudans' purchase of a property in […]
