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	2025 First-tier Tribunal (Tax)
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2025 First-tier Tribunal (Tax)

January

• Barclays Bank PLC v Revenue and Customs (Partial Closure Notice - identification of conclusion and reasons - TowerMCashback, Investect and Fidex applied, permission to amend statement of case to add another reason) [2025] UKFTT 27 (TC) (09 January 2025)
• Convergence Management Consultants Ltd v Revenue and Customs (INCOME TAX - CJRS - whether recoverable by HMRC - whether claim could be based on earnings "reasonably expected" to be paid - whether individual was a fixed rate employee - whether Fifth Direction changed the position - Six and Seventh Directions also considered) [2025] UKFTT 22 (TC) (09 January 2025)
• Global by Nature Ltd v Revenue and Customs (VAT - food - whether products standard rated as "sports drinks") [2025] UKFTT 24 (TC) (9 January 2025)
• Harbron Recruit Ltd v Revenue and Customs (Construction Industry Scheme - interaction between CIS and the agency rules - appellant misunderstood the interaction - whether acted with reasonable care - Tribunal's jurisdiction under Condition A of CIS regs) [2025] UKFTT 23 (TC) (09 January 2025)
• Johnson v Revenue and Customs (STAMP DUTY LAND TAX - annexe to main house with interconnecting door - whether property purchased as single dwelling or whether multiple dwellings relief applies - whether annexe suitable to be used as single dwelling - privacy and security - whether security door braces between main house and annexe constitute modification to the property - nature of chargeable interest acquired - multifactoral assessment taking into account all the facts and circumstances - the objective observer test - Fiander & Brower v HMRC and Lodson Preston Ltd & AKA Developments Greenview Ltd v HMRC considered and applied) [2025] UKFTT 50 (TC) (16 January 2025)
• Kolosov v Revenue and Customs (EXCISE DUTY - assessment to excise duty as goods (counterfeit tobacco) held outside a duty suspension arrangement - no evidence that duty paid - arrangement entered between Appellant and others - Appellant received goods at employer's premises and locked goods there following delivery - whether Appellant held, handled or had any involvement in the goods - Dawson's (Wales) Ltd, Davison & Robinson, WR and Prefect considered and applied - excise duty point - no earlier duty point identified - absence of innocent agent defence or explanation) [2025] UKFTT 29 (TC) (09 January 2025)
• Lautoka Vintage Ltd v Director for Border Revenue (CUSTOMS - seizure of goods - refusal to restore - decision based primarily on alleged failure to prove ownership of goods - whether decision was unreasonable - proportionality) [2025] UKFTT 25 (TC) (09 January 2025)
• Lyczkowski v Revenue and Customs (CUSTOMS & EXCISE DUTY - civil evasion penalty - tobacco products seized - no challenge to legality of the seizure - goods duly condemned as forfeit - whether penalty correctly applied - appeal solely on basis of inability to pay penalty) [2025] UKFTT 30 (TC) (09 January 2025)
• Mayet v Revenue and Customs (INCOME TAX - discovery assessments - did HMRC reasonably consider that funds deposited in private bank account held in the UK and Isle of Man were undeclared income from trade - has Appellant failed to declare foreign income - are assessments made in accordance to statutory requirements - has Appellant evidenced that reasonable conclusion to be wrong - does behaviour justify longer assessment time limits - PENALTIES - behaviour justifying assessments also justifying penalties) [2025] UKFTT 52 (TC) (16 January 2025)
• Narayanasamy v Revenue & Customs (COSTS - wasted costs claim - withdrawal of decision by HMRC - promoted by misunderstanding between parties - no unreasonable conduct in proceedings) [2025] UKFTT 21 (TC) (08 January 2025)
• Odfjell Technology (UK) Ltd v Revenue and Customs (National Insurance - Secondary Class 1 National Insurance contributions - Host Employer regulations - whether on the facts Appellant provides day-to-day direction/control of employees of foreign employer - whether operator also provides direction/control) [2025] UKFTT 28 (TC) (09 January 2025)
• SWG Polymer Services Ltd v Revenue and Customs (INCOME TAX - CJRS - whether recoverable by HMRC - director worked during the period of the claim) [2025] UKFTT 26 (TC) (09 January 2025)
• Trenbe UK Ltd v Revenue and Customs (Procedure - Case management - Appellants applications to (i) amend grounds of appeal to include a new appeal; (ii) admit late appeal; (iii) amend grounds of appeal to expressly refer to time limits and validity of assessments; and (iv) for appeal to be determined by reference to sample documents - Respondents' application to amend Statement of Case) [2025] UKFTT 20 (TC) (08 January 2025)
• Yaxley v Revenue and Customs (Strike out - jurisdiction - r8(2)(a) - amendment to tax return - top slicing relief - overpayment relief claim) [2025] UKFTT 51 (TC) (16 January 2025)