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• O’Neill Wetsuits Ltd v The Commissioners for HMRC First-tier Tribunal (Tax Chamber) [2024] UKFTT 1071 (TC) 28 Nov 2024 Matching text sample:

  Neutral Citation: [2024] UKFTT 001071 (TC) Case Number: TC09362 FIRST-TIER TRIBUNAL TAX CHAMBER [Taylor House] Appeal reference: TC/2023/00537 CUSTOMS DUTY – tariff classification – wetsuits imported into the United Kingdom by the Appellant – neoprene wetsuits covered with textile – the Harmonized Commodity Description and Coding System developed by the World Customs Organisation (‘the Harmonized System’) – the Explanatory Notes to the Harmonized System (‘HSENs’) – method of classification – the General Rules for the Interpretation of the Harmonized System (‘GIRs’) – rule 3(b) of the GIRs – the essential character of a wetsuit – what the primary constituent material of a wetsuits is – the relationship between the tariff notes and the GIRs – the relevance of Commission Regulation (EC) 2345/2003 concerning the classification of certain goods in the Combined Nomenclature – Sola Wetsuits & Leisurewear Ltd v C & E Comrs – Appeal allowed Heard on: 24 October 2024 Judgment date: 28...

• People Services Solution Ltd v The Commissioners for HMRC First-tier Tribunal (Tax Chamber) [2023] UKFTT 786 (TC) 22 Sep 2023 Matching text sample:

  Neutral Citation: [2023] UKFTT 00786 (TC) Case Number: TC08939 FIRST-TIER TRIBUNAL TAX CHAMBER Glasgow Tribunal Centre George House, Edinburgh Appeal reference: TC/2022/02706, TC/2022/02708, TC/2022/03949 LATE APPEAL – Martland considered – length of delay – whether serious or significant –serious but not significant – whether good reason for delay – yes – whether late appeals appropriate in all the circumstances – yes – applications allowed – appeals admitted Heard on: 21 June 2023 & 24 August 2023 Judgment date: 22 September 2023 Before TRIBUNAL JUDGE ANNE SCOTT

• Peter Gould v The Commissioners for HMRC First-tier Tribunal (Tax Chamber) [2022] UKFTT 431 (TC) 01 Nov 2022 Matching text sample:

  Neutral Citation: [2022] UKFTT 00431 (TC) Case Number: TC08647 FIRST-TIER TRIBUNAL TAX CHAMBER By remote video/ hearing Appeal reference: TC/ 2020/02844 Interim dividend – payment to shareholders on different dates - whether later dividend due and payable when first dividend paid – no Heard on: 29 and 30 September 2022 Judgment date: 01 November 2022 BETWEEN PETER GOULD Appellant -and- THE COMMISSIONERS FOR

• GCH Corporation Ltd & Ors v The Commissioners for HMRC First-tier Tribunal (Tax Chamber) [2024] UKFTT 922 (TC) 17 Oct 2024 Matching text sample:

  Neutral Citation: [2024] UKFTT 00922 (TC) Case Number: TC09318 FIRST-TIER TRIBUNAL TAX CHAMBER Taylor House, London Appeal Reference: TC/2020/03466 TC/2020/03467 TC/2020/02099 TC/2020/02101 TC/2020/02103 CAPITAL GAINS TAX – whether limited liability partnership carried on “a trade or business with a view to profit” for the purposes of s 59A(1) TCGA 1992, discovery assessments – whether “discovery” made for the purpose of s 29 TMA 1970. Appeal allowed. Heard on: 19-22 September 2023 Judgment date: 17 October 2024 Before JUDGE VIMAL TILAKAPALA MEMBER JO NEILL Between

• John Douglas Wardle v The Commissioners for HMRC First-tier Tribunal (Tax Chamber) [2024] UKFTT 543 (TC) 19 Jun 2024 Matching text sample:

  Neutral Citation: [2024] UKFTT 00543 (TC) Case Number: TC09213 FIRST-TIER TRIBUNAL TAX CHAMBER By remote video Appeal reference: TC/2023/08497 Capital gains tax - Entrepreneurs’ Relief (later titled Business Asset Disposal Relief)– whether commenced trading – yes - appeal allowed Heard on: 28 February (reading day), 29 February & 1 March 2024 Judgment date: 19 June 2024 Before TRIBUNAL JUDGE NEWSTEAD TAYLOR MR IAN SHEARER Between MR JOHN DOUGLAS WARDLE Appellant and

• Hillhead Limited v The Commissioners for HMRC First-tier Tribunal (Tax Chamber) [2023] UKFTT 215 (TC) 21 Feb 2023 Matching text sample:

  Neutral Citation: [2023] UKFTT 00215 (TC) Case Number: TC08741 FIRST-TIER TRIBUNAL TAX CHAMBER Taylor House, London Appeal references: TC/2021/00444 TC/2021/00445 VAT – Same individual sole director and shareholder of both appellants – Whether transactions of either or both appellants connected to fraudulent tax losses – Yes – Whether either or both appellants knew or should have known of such connection – Yes – Appeals dismissed Heard on: 17 – 20 and 24 January 2023 Judgment date: 21 February 2023 Before TRIBUNAL JUDGE JOHN BROOKS GILL HUNTER Between HILLHEAD LIMITED HILLHEAD PLANT LIMITED

• City Plant Ltd v Commissioners for HMRC First-tier Tribunal (Tax Chamber) [2023] UKFTT 414 (TC) 10 May 2023 Matching text sample:

  Neutral Citation: [2023] UKFTT 00414 (TC) Case Number: TC08815 FIRST-TIER TRIBUNAL TAX CHAMBER By remote video hearing Appeal reference: TC/2020/02978 Landfill Tax – application for permission to appeal out of time - section 54G(6) Finance Act 1996 – appeal extremely (in excess of 7 years) late – no reasonable explanation for delay – permission refused Heard on: 19 December 2022 Judgment date: 10 May 2023 Before TRIBUNAL JUDGE MARK BALDWIN Between CITY PLANT LTD Appellant and THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS Respondent

• Brac Saajan Exchange Ltd & Ors v The Commissioners for HMRC First-tier Tribunal (Tax Chamber) [2022] UKFTT 180 (TC) 09 Jun 2022 Matching text sample:

  Neutral Citation: [2022] UKFTT 00180 (TC) Case Number: TC08505 FIRST-TIER TRIBUNAL TAX CHAMBER By remote video hearing Appeal references: TC/2021/02763;TC/2021/02909 TC/2021/02908;TC/2021/02768 TC/2021/02767;TC/2021/02766 TC/2021/02816;TC/2022/01046 MONEY LAUNDERING – cancellation of registration of the corporate appellant – decisions that six of the individual appellants not fit and proper persons – prohibition notices issued to three appellants – whether a breach of Reg 18, Reg 19, Reg 28, Reg 33, Reg 35, Reg 57 and/or Reg 58 – reliability of HMRC’s evidence – jurisdiction of the Tribunal – meaning of “officer” – all appeals allowed Heard on: 1-14 April 2022 Judgment date: 09 June 2022 Before TRIBUNAL JUDGE ANNE REDSTON Between BRAC SAAJAN EXCHANGE LTD ABDUS SALAM RAIS AHMAD

• Sharon Suttle v The Commissioners for HMRC First-tier Tribunal (Tax Chamber) [2023] UKFTT 873 (TC) 26 Sep 2023 Matching text sample:

  Neutral Citation: [2023] UKFTT 00873 (TC) Case Number: TC08950 FIRST-TIER TRIBUNAL TAX CHAMBER Taylor House, 88 Rosebery Avenue, London EC1R 4QU Appeal reference: TC/2018/01394 TC/2018/01404 PERSONAL LIABILITY NOTICES – Appellants were directors of employment intermediary company – HMRC decided that company had underdeclared tax by understating hours worked and paying false or inflated tax-free expenses – whether there were inaccuracies in company’s returns – whether deliberate – whether attributable to the Appellants – held – inaccuracies in returns, but not deliberate – appeal allowed Heard on: 6 to 15 December 2022 Judgment date: 26 September 2023 Before TRIBUNAL JUDGE JEANETTE ZAMAN TRIBUNAL MEMBER JANE SHILLAKER Between SHARON SUTTLE