Field Court Tax Chambers

The first UK Tax Bulletin of 2022 is now available. In this issue, Peter Vaines discusses the comments by both STEP and the OTS on HMRC’s Reliance Statement and the perils of relying on HMRC’s guidance. He also covers a rare and potentially significant win for the taxpayer on the matter of tax deductions wholly and exclusively for the purposes of a trade. HMRC has been busy in the Court of Appeal in the long-awaited case of Embiricos v HMRC and Peter gives us plenty of food for thought on the ramifications of this judgement. In addition, the judgements in Charman v HMRC and Centrica Overseas Holdings Limited v HMRC shed some light on the timing of a right to acquire employee-related shares and options and the need for proper “corporate plumbing”. All of this and the latest rates of interest and inflation can be found here or on the Field Court Tax Chambers website.

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