Tax analysis: In HMRC v Moir Management, the First-tier Tax Tribunal (FTT) held that a UK company was a promoter of notifiable arrangements under the disclosure of tax avoidance schemes (DOTAS) rules and had failed both to comply with its obligation to notify HMRC of those arrangements and to respond to a pre-disclosure enquiry notice. The FTT rejected any claim of reasonable excuse and imposed penalties totalling £1.6m under section 98C of the Taxes Management Act 1970 (TMA 1970).

Tax analysis: In Chelsea Cloisters Management Ltd v HMRC, the First-tier Tax Tribunal (FTT) concluded that it had no jurisdiction in respect of a disputed application of an extra-statutory concession. The FTT however opined that if it did have jurisdiction, it would have found in favour of the taxpayer.

Tax analysis: In Eurocent (Buckingham) Ltd v HMRC, the First-tier Tax Tribunal (FTT) allowed the appellant’s appeal in part, finding that certain invoices met the statutory requirements for the contents of a valid VAT invoice. The FTT also rejected HMRC’s contention that it was entitled to reject input tax claims, using its discretion under the VAT Regulations 1995, SI 1995/2518, reg 29(2), even if the VAT invoice was valid.

Pensions analysis: On 25 June 2026, a first-tier decision in the General Regulatory Tribunal was handed down in the case of Involved Social Impact Projects Ltd v The Pensions Regulator. [MD1.1] The First-tier Tribunal (FTT) partially allowed the employer’s appeal against the escalating penalty notice issued by the Pensions Regulator (TPR), holding that although TPR had been entitled to issue both the unpaid contributions notice and fixed penalty notice under the Pensions Act 2008 (PA 2008), it had failed properly to’ verify information supplied by National Employment Savings Trust (NEST) when assessing the level of the escalating penalty. The decision highlights the importance of regulators corroborating third-party data before imposing sanctions and demonstrates the practical consequences of inaccurate pension administration records. It also underlines the value of effective communication by pension providers where employers seek to remedy automatic enrolment breaches. Produced in partnership with Paul Carney of Shoosmiths LLP.

Tax analysis: In Acorn Venture Ltd v HMRC, the First-tier Tax Tribunal (FTT) allowed in part the company’s claim to capital allowances for its expenditure on camping pods for use by participants in school trips.

Tax analysis: In Exclusive Promotions and Fox, the First-tier Tax Tribunal (FTT) dismissed appeals against penalties for failing to pay the amounts specified in accelerated payment notices (APNs) on time and confirmed that (barring an obvious or gross procedural error) neither a belief in the invalidity of an APN nor being granted interim relief from enforcement of an APN pending resolution of a related judicial review (JR) dispute constitute a reasonable excuse for not paying an APN on time. The FTT also provided guidance that in certain circumstances, HMRC’s failure to consider and respond to representations may mean that the time limit for paying an APN doesn’t begin to run.

Tax analysis: In BGC Services Holdings LLP v HMRC, the First-tier Tribunal (FTT) refused HMRC permission to appeal to the Upper Tribunal (UT) against two case management decisions (i) refusing HMRC’s request for further and better particulars from the taxpayer, and (ii) requiring HMRC to particularise in its statement of case how salaried members rules conditions were met for which partners, how the determinations of over £96m were calculated, and the basis for alleging deliberate or careless behaviour on the part of the taxpayer. HMRC now has the right to appeal directly to the UT for permission to appeal the decisions.

Tax analysis: In Carbon Six Engineering Ltd v HMRC, the First-tier Tax Tribunal (FTT) refused HMRC’s application to set aside a barring order made following its failure to comply with an ‘unless order’.

Tax analysis: In County Insurance Services Ltd v HMRC, the First-tier Tax Tribunal (FTT) held that goodwill acquired by a company on the incorporation of an insurance business partnership in 2013 was created before 1 April 2002 and therefore fell outside the corporate intangible fixed assets regime.

Tax analysis: In The Executors of KDL Beresford the First-tier Tax Tribunal (FTT) upheld HMRC’s determination that business property relief from inheritance tax was not available in respect of shares in a company. The company’s subsidiary’s activity of letting of parts of a commercial property as serviced offices was ‘wholly or mainly making or holding of investments’.

Tax analysis: In Generator Power, the First-tier Tax Tribunal (FTT) refused the taxpayer’s application for costs because it was not persuaded that HMRC had acted unreasonably by not withdrawing from the case earlier.

Tax analysis: In NNB Generation Company (NNB), the First-tier Tax Tribunal (FTT) refused the taxpayer’s application to recategorise its appeal against an information notice as a complex case even though the underlying HMRC enquiry into substantial claims (of approximately £2bn) for research and development (R&D) allowances for the Hinkley Point C project was technically demanding and extensive.