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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 corporation tax; employment taxes; and VAT.

Tax overpayment claim on foreign income found to be within time limit
  • Nov 2025
The Court of Appeal upheld the decision of the High Court that the trigger point for the overpayment claim was a later date than HMRC had argued. The taxpayer had therefore made their claim for the overpayment of corporation tax paid within the relevant time period...
Appeals dismissed on PAYE and employer NICs
  • Nov 2025
The First-tier Tribunal (FTT) has found that money did not have to be at an employee’s absolute disposal to be classed as earnings for income tax and national insurance contributions (NIC) purposes under the definitions in the legislation...
Interest on VAT element
  • Nov 2025
In the case of Pharos Offshore Group Ltd v Keynvor Morlift Ltd, the High Court has handed down a judgment dealing with consequential matters following the main judgment in a contract dispute whereby the High Court determined that the amount owed to Pharos, after setting off KML’s counterclaim, net of interest, was £495,668.68 inclusive of VAT...
Input tax apportionment methodology
  • Nov 2025
The Hippodrome in Leicester Square has casinos, bars and restaurants, and a theatre. In 2022, the First-tier Tribunal (FTT) agreed with Hippodrome Casino Ltd (HCL) that a floorspace-based standard method override (which improved HCL’s input tax recovery) was a better reflection of the use of HCL’s costs than the standard method, based on turnover...
VAT treatment of supplies of locum doctors
  • Nov 2025
HMRC issued a decision in August 2021 to Isle of Wight NHS Trust (the Trust) that the supply of locum medical practitioners to the Trust by agencies was not an exempt supply under Item 5, Group 7, Schedule 9, VATA 1994, which exempts “the provision of a deputy for a person registered in the register of medical practitioners”...
VAT liability of nitrous oxide for culinary use
  • Nov 2025
Telamara Limited supplied nitrous oxide (N2O) in canisters intended exclusively for culinary use as cream chargers, used for whipping cream and making foams and mousses, etc...
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Personal tax

There are no updates this month.

Income tax: Appeal dismissed on sporting image rights
  • Oct 2025
The First-tier Tribunal (FTT) has found that it was the individual, not the company he had assigned his image rights to, that had entered into sponsorship agreements. Therefore, the income was taxable on him...
Inheritance tax: FTT rules on the meaning of life (for IHT purposes)
  • Oct 2025
The First-tier Tribunal (FTT) has found that ‘life’ in the IHT legislation can refer both to human life, for an individual settlor, and live companies for corporate settlors...
Property tax: Taxpayers win appeal on multiple dwellings relief
  • Oct 2025
The First-tier Tribunal (FTT) has found that an annexe qualified as a separate dwelling for stamp duty land tax (SDLT) purposes, and multiple dwellings relief (MDR) applied...
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Tax compliance and investigations

This month covers appeals, disputes and investigations. 

Late appeal not admitted
  • Nov 2025
The First-tier Tribunal (FTT) refused to admit a late appeal, as the taxpayer was attempting to appeal its own error rather than that of HMRC...
FTT orders HMRC to disclose documents
  • Nov 2025
The First-tier Tribunal (FTT) found that HMRC should provide most of the requested documents to the taxpayers, but not internal HMRC documents...
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More in tax compliance and investigation

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

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