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J Boulting v HMRC [2025] UKFTT 1272 (J Boulting v HMRC [2025] UKFTT 1272 )

Tax Cases and Appeals Crown Copyright
2025-10-24
Capital Gains Tax - company purchase of own shares - part of related arrangements which led to removal of director/shareholder - whether purchase of own shares was for the purpose of the benefit of a relevant trade
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Dialog Semiconductor Ltd v HMRC [2025] UKFTT 1188 (Dialog Semiconductor Ltd v HMRC [2025] UKFTT 1188 )

Tax Cases and Appeals Crown Copyright
2025-10-03
Corporation tax - section 22(1)(c) Taxation of Chargeable Gains Act 1992 - surrender - termination fee - merger agreement - Delaware law - appeal allowed
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P Collingwood v HMRC [2025] UKFTT 1065

Tax Cases and Appeals Crown Copyright
2025-08-28
Income tax - payments received from sponsorship agreements reported through Appellant's company - assignment of intellectual property rights between the Appellant and his company - the absence of the concept of "Image Rights" under English law
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Haworth v HMRC [2025] EWCA Civ. 822

Tax Cases and Appeals Crown Copyright
2025-07-01
The England and Wales Court of Appeal found that a trust’s “place of effective management” was located in the UK, where general management of the trust was undertaken, and not in the overseas jurisdiction, where the trustees had been appointed
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Moffat v HMRC [2025] UKFTT 663

Tax Cases and Appeals Crown Copyright
2025-06-05
CGT - entrepreneurs' relief - whether "holding company of a trading group" carrying on activities which did not include to a substantial extent - s165A(8) TCGA 1992 - no - appeal dismissed
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Beard v HMRC [2025] EWCA Civ 385

Tax Cases and Appeals Crown Copyright
2025-05-02
The Court of Appeal rejected the taxpayer’s appeal, upholding the earlier UT and FTT decisions that distributions received were dividends, but were not of a capital nature and were therefore chargeable to income tax
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Eyre and another v HMRC [2025] UKFTT 461

Tax Cases and Appeals Crown Copyright
2025-04-23
Income Tax & CGT - residential property - whether an adventure in the nature of a trade - whether principal private residence - appeals allowed
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Gary Quillan v HMRC [2025] TC09487

Tax Cases and Appeals Crown Copyright
2025-04-11
Section 415 Income Tax (Trading and Other Income) Act 2005 – whether director’s loan was released – no – whether director’s loan was written off – no – appeal allowed
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Royal Bank of Canada v HMRC [2025] UKSC 2

Tax Cases and Appeals Crown Copyright
2025-02-12
Appeal concerns the allocation of taxing rights between the United Kingdom and Canada in respect of income earned from the sale of oil found in the UK Continental Shelf in the North Sea
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