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That was the year that was 2025 2025 was the year that ‘Celebrity Traitors’ captivated the nation; so much so that it looked like Rachel Reeves and Keir Starmer were inspired to betray their voters and kill their manifesto commitment to not raise taxes. As it happens, they couldn’t...
Tax and the City Review - November 2025 In Dialog, the FTT considers whether a break fee paid by a target to a bidder was a capital sum derived from an asset taxable under TCGA 1992 s 22(1)(c). The FTT in Boulting concludes that a company purchase of own shares was for the benefit of a relevant...
Podcast: Tax News: November 2025 Alex Sim joined Zoe Andrews to discuss three cases of the FTT: Dialog (the tax treatment of break fees), Boulting (purchase of own shares was not a distribution) and Ferrero (the VAT treatment of Nutella biscuits).
The contract prevails: Supreme Court confirms there is no principle of deemed fulfilment of conditions precedent under English law The Supreme Court in King Crude Carriers & Ors v Ridgebury November & Ors has unanimously overturned the Court of Appeal and settled a long-debated point in English contract law, holding that the principle of ‘deemed fulfilment’ of conditions...
UK Tax dispute risks Unexpected tax liabilities are a key business risk.  For governments facing challenging fiscal environments, a tougher approach to tax compliance and enforcement can be a critical revenue raiser. The UK is no exception. This briefing outlines current...
Tax and the City Review - October 2025 Discussions are ongoing at the OECD/IF on the design of the ‘side-by-side’ system. In its unanimous judgment in Prudential, the Supreme Court provides much-needed clarity on the interaction of the VAT grouping rules and the time of supply rules which...
Podcast: Tax News: October 2025 Sarah Osprey joined Zoe Andrews and Tanja Velling to talk about tax disputes and our exciting new project in this area.
Tax Disputes: from assessment to FTT
Tax and the City Review - September 2025 In Currys, the FTT decides that the taxpayer had not disposed of the goodwill before leaving the chargeable gains group and so a degrouping charge under TCGA 1992 section 179 arose. HMRC plan to increase the compliance burden on financial institutions and...
Podcast: Tax News: September 2025 Sarah Osprey joined Zoe Andrews and Tanja Velling to talk about tax disputes and our exciting new project in this area.
Podcast: Tax News: July 2025 Zoe Andrews and Tanja Velling discuss the following recent cases:
Tax and the City Review - July 2025 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider: The Upper Tribunal’s decision in Osmond, in favour of the taxpayers, that the income tax advantage was an effect, not a main purpose, of the transaction and so the transactions...
Tax News: The One Big Beautiful Bill In this special episode of our Tax News podcast, Zoe Andrews and Tanja Velling are joined by Arvind Ravichandran, Tax Partner at Cravath, Swaine & Moore LLP, to discuss the significant impact the proposed section 899 could have on US capital markets.
Tax and the City Review - June 2025 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider: The test of whether foreign dividends received by an individual are income or capital as applied by the Court of Appeal in Alexander Beard. The Upper Tribunal’s decision in...
Podcast: Tax News: June 2025 Zoe Andrews and Tanja Velling discuss the Upper Tribunal’s decisions in Walkers Snack Foods on the VAT classification of “Sensations Poppadoms” and Rettig Heating Group, the judicial review of HMRC’s refusal of a late claim to set off a non-trading loan...