In this podcast, Zoe Andrews and Tanja Velling discuss HMRC’s draft guidance in relation to the large business notification of uncertain tax treatment for which draft legislation was published on “L-Day”, and four recent cases:
- the Court of Appeal’s decision in Ingenious Games (a sequel to the Ingenious Films litigation),
- the Court of Session’s decision in the employment-related securities case Vermilion,
- the Upper Tribunal’s decision in Centrica on investment management expenses, and
- the First-tier Tribunal’s decision in the latest unallowable purpose case, Kwik-Fit.
They also briefly mention the Upper Tribunal’s decision in KSM Henryk Zeman where public law arguments, normally the purview of judicial review, were permitted to be raised in a VAT appeal.
Text alternative. Tax news highlights: September 2021