Appeal regarding application of clawback relief for Help to Buy Scheme, s477C TCA 1997
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Appeal regarding definition of first time purchaser as part of the Help to Buy Scheme, s477C TCA 1997
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Appeal regarding treatment of certain travel expenses by Directors and a spouse where inadequate records were kept s114 TCA 1997
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Appeal regarding treatment of artists employment income s195 TCA 1997
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Appeal regarding assessment to DWT following a series of transactions involving transfer of shares and loan agreements s10 TCA 1997, s130 TCA 1997, s549 TCA 1997
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State aid – Article 107(1) TFEU – Tax rulings adopted by a Member State – Aid declared incompatible with the internal market – Obligation to recover that aid – Concept of ‘advantage’ – Determination of the reference framework – ‘Normal’ taxation under national law – Review by the Court of Justice of the interpretation and application of national law by the General Court of the European Union – Direct taxation – Strict interpretation – Powers of the European Commission – Obligation to state reasons – Legal classification of the facts – Concept of ‘abuse of law’ – Ex ante assessment by the tax authorities of the Member State concerned – Principle of legal certainty
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Penalties for failure to notify liability to CGT – appellant relied on case law which could not be found on any legal website – whether cases generated by artificial intelligence such as ChatGPT – yes, case law invented and not genuine – whether appellant had reasonable excuse for failure to notify – principles in Christine Perrin considered and applied – appeal dismissed
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Private Residence Relief - taxpayers bought land demolished existing house and build new dwelling house which they lived in as main residence then sold for gain - meaning of “period of ownership” used in apportionment relief - held - ownership referred to that of new house as opposed to land as HMRC argued - HMRC’s appeal against FTT decision dismissed
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Reference for a preliminary ruling . Directive 2006/112/EC – Article 53 – Services in respect of admissions to entertainment events – Place of supply of services – Streaming of interactive video sessions – Making available of a location and of the equipment necessary for the video capture of performances and for the implementation of accompaniment in order to provide quality performances
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Appeal by way of case stated regarding TAC determination (164TACD2022) regarding date of disposal for CGT purposes, s542 TCA 1997
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