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Admin
Avoidance
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Penalties should not be suspended
P Cox and D Cox (
TC9198
)
Importance of undertaking due diligence checks
Gary Turner (
TC9193
)
Costs allowed due to HMRC’s unreasonable conduct
A Ahmed (
TC9110
)
Unallowable tax avoidance purpose
JTI Acquisition Company (2011) Ltd v CRC,
Court of Appeal
, 13 June 2024
Both third party payments necessary for transfer
T Watts v CRC,
Upper Tribunal (Tax and Chancery Chamber)
, 12 June 2024
Business investment relief rules breached
B d’Angelin (
TC9186
)
Director should have known supply chain was fraudulent
A S Powar (
TC9175
)
Notices of requirement reasonably issued
Blocksure Ltd (in liquidation) and R Saggu (
TC9164
)
Anti-abuse provision in UK/Ireland double tax treaty
CRC v Burlington Loan Management DAC,
Upper Tribunal (Tax and Chancery Chamber)
, 31 May 2024
Inadvertent remittances are taxable
A Alimahomed (
TC9178
)
Wrong approach to third RMC stage test
CRC v Basic Broadcasting Ltd,
Upper Tribunal (Tax and Chancery Chamber)
, 7 June 2024
Cold ‘dip pots’ in a hot take away meal deal
Queenscourt Ltd (
TC9184
)
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Global 15% tax rate will not apply to US companies
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Maximum penalty due for failure to notify
Professional fees are not deductible
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Burden of proof when challenging a civil penalty
Deed of appointment was adequate proof
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This week's opinion: 15 January 2026
Global 15% tax rate will not apply to US companies
Visitor Levy Amendment Bill published
HMRC expands use of AI to counter tax avoidance
Consultation on proposed administrative amendments