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Practical Points

Every month, the Tax Faculty publishes short, practical pieces of guidance to help agents and practitioners in their day-to-day work.

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Business tax

This month covers partnership taxation and VAT.

Tax treatment of ‘capital interests’ held by individual partners in a UK LLP
  • Mar 2026
The Upper Tribunal (UT) has largely allowed HMRC’s appeal, and dismissed the taxpayers’ cross-appeal, in the case of Mark Benedict Holden v HMRC. The case concerns the tax treatment of individual members of a UK limited liability partnership (LLP) in respect of amounts identified as ‘capital interests’ in various LLP agreements...
Jurisdiction of First-tier Tribunal
  • Mar 2026
The Court of Appeal (CA) has considered the nature of the First-tier Tribunal’s (FTT’s) jurisdiction. HMRC had disallowed input tax claimed by FS Commercial Limited on the basis that it had not provided VAT invoices to support input tax recovery, as requested by HMRC...
Whether a supply was in the course of catering
  • Mar 2026
Slice of Pie Limited (SPL) supplied food to nurseries for lunches and afternoon teas. The food was supplied cooked and hot, with each component of the meal (protein, carbohydrate, vegetables, pudding, etc) delivered in separate containers...
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More in business tax

Exclusive Practical points: business tax March 2026
Exclusive Practical points: business tax February 2026
Exclusive Practical points: business tax January 2026
Exclusive Practical points: business tax December 2025
Practical Points archive

Personal tax

There are no updates this month.

Win for taxpayer on mixed use relief on large estate
  • Feb 2026
The taxpayer and her late husband bought a substantial property with one main dwelling, two smaller dwellings, equestrian facilities and 150 acres of land. HMRC opened an enquiry into the stamp duty land tax (SDLT) return, challenging the taxpayers’ view that this was a mixed-use property...
Win for taxpayer on multiple dwellings relief
  • Feb 2026
The First-tier Tribunal (FTT) has found on the facts that a house with an annex qualified as two separate dwellings. Multiple dwellings relief (MDR) therefore applied...
Court of Appeal dismisses taxpayer’s SDLT appeal
  • Feb 2026
The Court of Appeal (CA) has handed down its judgment in the stamp duty land tax (SDLT) case of The Tower One St George Wharf Limited. The case relates to a series of transactions for the transfer of an interest in a residential property from one group company to another...
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More in personal tax

Exclusive Practical points: personal tax February 2026
Exclusive Practical points: personal tax December 2025
Exclusive Practical points: personal tax October 2025
Exclusive Practical points: personal tax September 2025
Practical Points archive

Tax compliance and investigations

This month covers appeals, disputes and investigations and penalties.

Application for a late appeal
  • Mar 2026
In 2023, the First-tier Tribunal (FTT) refused Medpro Healthcare Limited (and others) permission to bring a VAT appeal against a penalty assessment and personal liability notices out of time...
Upper Tribunal sets aside “careless” and “deliberate” inaccuracy penalties
  • Mar 2026
On 19 January 2026, the Upper Tribunal (UT) issued its decision in the case of Delphi Derivatives Limited (in Members’ Voluntary Liquidation) v HMRC, which concerns penalties resulting from a failed tax avoidance scheme, involving the use of an employee benefit trust (EBT)...
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More in tax compliance and investigation

Exclusive Practical points: tax compliance and investigation March 2026
Exclusive Practical points: tax compliance and investigation February 2026
Exclusive Practical points: tax compliance and investigation December 2025
Exclusive Practical points: tax compliance and investigation November 2025
Practical Points archive

Tax administration

There are no updates this month.

Tax payments and repayments: Taxpayers fail to recover loan charge payments to HMRC
  • Oct 2025
The Upper Tribunal (UT) has found that taxpayers who used the Disguised Remuneration Repayment Scheme were not entitled to a refund, as HMRC would have had power to recover the amounts...
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More in tax administration

Exclusive Practical points: tax administration October 2025
Exclusive Practical points: tax administration 2023
Practical Points archive

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