1. Disclosures.

  2. Assessments, including time limits, discovery assessments and information powers.

  3. Penalty and interest claims.

  4. Residence and ordinary residence.

  5. Domicile and remittances to the UK.

  6. Sch E – whether contract for services or contract of services.

  7. Retirement relief.

  8. Rollover relief.

  9. Validity of further assessments – whether agreements reached in accordance with s 54 TMA 1970.

  10. Tribunal rules. Compliance, sanctions, costs and allocation as complex.

  11. Error or mistake claims – s 33 TMA 1970.

  12. Conditional or unconditional contracts – construction of agreements for the sale and purchase of interests in land, loan agreements and legal charges.

  13. Transactions otherwise than by way of bargains made at arm’s length – particularly in relation to share and loan transactions.

  14. Contract – acceptance of lesser sum in satisfaction of whole – mistake – whether clear and unambiguous language – whether acceptance binding – whether consideration – forbearance – whether fraud on third party payer by recovering whole from debtor – limitation period for enforcement of final and conclusive tax assessment.

  15. Contract – assignment – novation.

  16. Capital sums derived from assets – agricultural tenancies – compensation.

  17. Validity of bare trusts – whether beneficial interests transferred.

  18. Claims for indexation allowance on redeemable preference shares.

  19. Availability of the charity exemption – consideration of trust deeds and financial statements.

  20. Claims for allowable CGT losses on transactions particularly on share transactions.

  21. Intra-group distributions – capital distributions.

  22. Valid discharge of UK trustees so that trust exported from UK.

  23. Revenue representations – whether binding – MFK.

  24. Surrender or variation of leases.

  25. Partnership – co-ownership -guaranteed qualifying loans for CGT purposes.

  26. Advice on network instructions, policy documents and application of Revenue concessions.

  27. Guarantees and variations of contracts – promissory estoppel.

  28. CGT. Principal private residence exemption.

  29. Losses on loans to traders.

  30. Absolute entitlement.

  31. Value shifting.

  32. Qualifying corporate bonds.

  33. Directors duties and members voting rights.

  34. Res Judicata.

  35. VAT – transfer of lease of industrial estate – whether TOGC.

  36. VAT – legal services provided to Spanish client – whether non-UK residence certificate required before no VAT charge – reverse charge procedure.

  37. Share Option Schemes – Revenue approved – conditions.

  38. CGT – lease – grant of extension for no consideration – whether CGT liability.

  39. VAT – solicitor’s bill to corporate plaintiffs in liquidation – whether defendant should pay VAT element of solicitor’s bill – whether company in liquidation entitled to recover input tax – whether double recovery.

  40. Stamp duty – s 77(1) FA 1986 – share exchange – whether relief available.

  41. VAT – lease – surrender – reverse premium – whether VAT exempt.

  42. CGT – death – consequences.

  43. EIS Relief – s 304A ICTA 1988 – exchange of shares for partly paid shares in new parent company – whether relief maintained.

  44. VAT – advertising services supply by UK suppliers to Belgian recipient – definition of advertising services – whether VAT liability – variation of place of supply.

  45. VAT – input tax incurred before registration – whether entitled to repayment – conditions for voluntary registration – property owner or developer – conditions for option to tax.

  46. VAT – request for payment in advance of completion of purchase of freehold – whether VAT liability arises at exchange of contracts – time of supply – basic tax point.

  47. VAT – exemption – stables – licence to occupy land – additional services – whether incidental to licence or discrete element of supply.

  48. VAT – land – transfer for nil consideration – option to tax – waiver of requirement for consideration.

  49. Stamp duty – whether transaction formed part of a larger transaction or a series of transactions within s 34(4) FA 1958.

  50. CGT – purchase by company of own shares.

  51. CGT – merger of partnerships – no gain/no loss – rollover relief.

  52. VAT – voluntary registration – input tax on professional advisers’ fees in placing shares – preparatory acts attributable to business – whether taxable person – whether carrying on a business.

  53. Stamp duty – intra group transfer – group relief – s 42 FA 1930.

  54. VAT – sale of dental practice – whether exempt – whether TOGC – whether indemnity required.

  55. IHT – post-death variation of liabilities under will – whether within s 142(1) IHTA 1984.

  56. CGT – reorganisation – taxpayers sold shares in Co A to Co B in consideration of cash and earn-out rights in Co B of shares or debentures – Co B purchased by Co C – whether would remain within reorganisation provisions if earn-out rights in Co B exchanged for earn-out rights in Co C or actual shares or debentures in Co C – s 138A TCGA 1992.
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