- Disclosures.
- Assessments, including time limits, discovery assessments and information powers.
- Penalty and interest claims.
- Residence and ordinary residence.
- Domicile and remittances to the UK.
- Sch E – whether contract for services or contract of services.
- Retirement relief.
- Rollover relief.
- Validity of further assessments – whether agreements reached in accordance with s 54 TMA 1970.
- Tribunal rules. Compliance, sanctions, costs and allocation as complex.
- Error or mistake claims – s 33 TMA 1970.
- Conditional or unconditional contracts – construction of agreements for the sale and purchase of interests in land, loan agreements and legal charges.
- Transactions otherwise than by way of bargains made at arm’s length – particularly in relation to share and loan transactions.
- 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.
- Contract – assignment – novation.
- Capital sums derived from assets – agricultural tenancies – compensation.
- Validity of bare trusts – whether beneficial interests transferred.
- Claims for indexation allowance on redeemable preference shares.
- Availability of the charity exemption – consideration of trust deeds and financial statements.
- Claims for allowable CGT losses on transactions particularly on share transactions.
- Intra-group distributions – capital distributions.
- Valid discharge of UK trustees so that trust exported from UK.
- Revenue representations – whether binding – MFK.
- Surrender or variation of leases.
- Partnership – co-ownership -guaranteed qualifying loans for CGT purposes.
- Advice on network instructions, policy documents and application of Revenue concessions.
- Guarantees and variations of contracts – promissory estoppel.
- CGT. Principal private residence exemption.
- Losses on loans to traders.
- Absolute entitlement.
- Value shifting.
- Qualifying corporate bonds.
- Directors duties and members voting rights.
- Res Judicata.
- VAT – transfer of lease of industrial estate – whether TOGC.
- VAT – legal services provided to Spanish client – whether non-UK residence certificate required before no VAT charge – reverse charge procedure.
- Share Option Schemes – Revenue approved – conditions.
- CGT – lease – grant of extension for no consideration – whether CGT liability.
- 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.
- Stamp duty – s 77(1) FA 1986 – share exchange – whether relief available.
- VAT – lease – surrender – reverse premium – whether VAT exempt.
- CGT – death – consequences.
- EIS Relief – s 304A ICTA 1988 – exchange of shares for partly paid shares in new parent company – whether relief maintained.
- VAT – advertising services supply by UK suppliers to Belgian recipient – definition of advertising services – whether VAT liability – variation of place of supply.
- VAT – input tax incurred before registration – whether entitled to repayment – conditions for voluntary registration – property owner or developer – conditions for option to tax.
- 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.
- VAT – exemption – stables – licence to occupy land – additional services – whether incidental to licence or discrete element of supply.
- VAT – land – transfer for nil consideration – option to tax – waiver of requirement for consideration.
- Stamp duty – whether transaction formed part of a larger transaction or a series of transactions within s 34(4) FA 1958.
- CGT – purchase by company of own shares.
- CGT – merger of partnerships – no gain/no loss – rollover relief.
- 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.
- Stamp duty – intra group transfer – group relief – s 42 FA 1930.
- VAT – sale of dental practice – whether exempt – whether TOGC – whether indemnity required.
- IHT – post-death variation of liabilities under will – whether within s 142(1) IHTA 1984.
- 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.