Philip Ridgway

1 month ago | taxjournal.com | David Whiscombe |Chris Mortimer |Philip Ridgway |Elena Rowlands

Adequacy of reasons given by FTT: In H Rafferty v HMRC [2025] UKUT 63 (TCC) (19 February) the taxpayer was given limited permission to appeal to the UT against closure notices assessments and penalties. The decision of the UT in rejecting the appeal is largely fact specific but paras 40 onwards are worth reading for their discussion of the consequences of an FTT not giving adequate reasons for its decision.

1 month ago | taxjournal.com | David Whiscombe |Chris Mortimer |Philip Ridgway |Elena Rowlands

In Chelsea Cloisters Management Ltd v HMRC [2025] UKFTT 205 (TC) (12 February) the FTT concluded that it had no jurisdiction in respect of a disputed application of an extra-statutory concession. The FTT however opined that if it did have jurisdiction it would have found in favour of the taxpayer. Chelsea Cloisters Management Ltd (CCML) is a management company for a property in London known as Chelsea Cloisters.

1 month ago | taxjournal.com | Philip Ridgway |David Whiscombe |Chris Mortimer |Elena Rowlands

When did we let this happen? And more fundamentally, why do we let this happen? HMRC have gone back on their decision on how to tax limited partners. In effect, a year ago they changed the law to impose tax, and now they’ve changed it back again (see Tax Journal, 14 February 2025). Hurrah for common sense. But all this was done without spilling a single drop of legislative ink. Even in the mess that is the US, an elected person makes an executive order which can be challenged quickly in the courts.

1 month ago | taxjournal.com | David Whiscombe |Chris Mortimer |Philip Ridgway |Elena Rowlands

HMRC have published the GAAR Advisory Panel’s opinion on arrangements involving transfers of amounts into employee trusts (IHTA 1984 s 28) which sought to reduce or eliminate IHT. The deceased had put around £1m into a company she had set up. The company established an employee trust and separately allocated shares to the deceased which were then gifted into the trust. The aim was that IHT on the deceased’s estate would be significantly reduced because of the effect of s 28.

1 month ago | taxjournal.com | David Whiscombe |Chris Mortimer |Philip Ridgway |Elena Rowlands

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