Tax new highlights: September 2021

In this podcast, Zoe Andrews and Tanja Velling discuss HMRC’s draft guidance in relation to the large business notification of uncertain tax treatment for which draft legislation was published on “L-Day”, and four recent cases:

• the Court of Appeal’s decision in Ingenious Games (a sequel to the Ingenious Films litigation);
• the Court of Session’s decision in the employment-related securities case Vermilion;
• the Upper Tribunal’s decision in Centrica on investment management expenses; and 
• the First-tier Tribunal’s decision in the latest unallowable purpose case, Kwik-Fit.

They also briefly mention the Upper Tribunal’s decision in KSM Henryk Zeman where public law arguments, normally the purview of judicial review, were permitted to be raised in a VAT appeal.