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Burden of proof rests mainly with HMRC
CRC v Sintra Global Inc and another,
Upper Tribunal (Tax and Chancery Division)
, 7 November 2024
Expenditure was neither subsidised nor contracted out
Stage One Creative Services Ltd (
TC9358
)
Alternative dispute resolution may assist situation
R Crawford (
TC9338
)
Property was suitable for use as a dwelling
R Ball and S Torokoff (
FTSTC6
)
Taxpayer’s application for anonymity rejected
CRC v The Taxpayer and others,
Upper Tribunal (Tax and Chancery Chamber),
19 November 2024
Remuneration arrangements not above suspicion
K (on the application of Payeworx Ltd) v CRC,
King’s Bench Division
, 8 November 2024
Temporal limit of advance pricing agreement
R (on the application of Refinitiv Ltd and others) v CRC,
Court of Appeal
, 15 November 2024
Main purpose of loan was tax mitigation
Syngenta Holdings Ltd (
TC9346
)
Exporter entitled to zero rate goods
Procurement International Ltd (
TC9330
)
Health services supplied to local authorities
R (oao Midlands Partnership University NHS Foundation Trust) v CRC,
Upper Tribunal (Tax and Chancery Chamber)
, 25 October 2024
Contract was outside the ten-year period
R (on the application of Cobalt Data Centre 2 LLP and another) v CRC,
Supreme Court
, 20 November 2024
Avoidance was a main purpose of the transfer
Tower One St George Wharf Ltd v CRC,
Upper Tribunal (Tax and Chancery Chamber),
20 November 2024
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This week's opinion: 15 October 2026
Agent reference number checks paused
Court of Appeal decision in Bolt stands
Clarify NICs and state pension entitlement, says ATT
Patent box relief claimed in 2024-25 rises to £2.28bn