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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 and VAT.

Taxpayers’ appeal on partnership and intangible fixed assets dismissed
  • Apr 2026
The Court of Appeal (CA) has unanimously dismissed the taxpayers’ appeal in the case of Muller UK & Ireland Group LLP and others v HMRC. In 2013, three UK resident companies incorporated a limited liability partnership (LLP) and transferred their trades and certain assets to it...
Early redemption of loan notes and imported losses rules
  • Apr 2026
The Upper Tribunal (UT) upheld the decision of the First-tier Tribunal (FTT) that the compensatory element of an early redemption as an imported loss was disallowable, but concluded that relief was available for the costs referable to the post-migration period...
Reduced VAT rate for public EV charging
  • Apr 2026
Charge My Street Limited (CMS) supplies electric vehicle (EV) charging to EVs at its charging stations in public places. CMS considered the reduced VAT rate of 5% applied to its supplies, on the basis that they fell within the de minimis limit for supplies of electricity and so were deemed to be for “domestic use”...
Pre-registration VAT
  • Apr 2026
From 2009, Aspire in the Community (ACL) provided VAT exempt welfare services. Aspire in the Community Services Limited (ACSL) was incorporated in 2011, and later became a supplier to local authorities and clinical commissioning groups...
VAT treatment of plan bundles
  • Apr 2026
Lycamobile UK Limited sold ‘plan bundles’ to UK customers, comprising rights to access telecommunication services, that is, telephone calls, text messages, and data...
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Personal tax

This month covers savings and interest.

Decision on compensation and interest upheld
  • Apr 2026
The Upper Tribunal (UT) has found that the First-tier Tribunal (FTT) was correct to regard compensation paid for mis-sold interest rate hedging products as taxable...
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Tax compliance and investigations

This month covers appeals, disputes and investigations and penalties.

HMRC’s appeal dismissed in discovery case on time limits
  • Apr 2026
The Upper Tribunal (UT) has upheld the First-tier Tribunal’s (FTT) finding that HMRC’s assessments were invalid, as not all of the behaviour was deliberate. Each part of the assessment must meet the correct behavioural threshold for the relevant time limit...
Appeal allowed on extended time limit for carry-back losses
  • Apr 2026
The taxpayer successfully argued that he was in time to amend carry forward claims to carry-back claims, and that HMRC had made an appealable decision...
Discovery assessments upheld on taxpayer who used repayment agent
  • Apr 2026
The taxpayer was paid through pay as you earn (PAYE), and wanted to claim employment expenses in excess of what could be included in his PAYE code. He signed up with an online agent who was due to arrange the tax refund for him...
Extended time limit did not apply
  • Apr 2026
This case was remitted from the Upper Tribunal (UT) to the First-tier Tribunal (FTT) for a determination on taxpayer behaviour. If the taxpayers had made a deliberate inaccuracy, then the extended time limit for investigation would have applied...
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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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