In this podcast, Zoe Andrews and Tanja Velling discuss HMRC’s draft guidance in relation to the large business notification of uncertain tax treatment for which draft legislation was published on “L-Day”, and four recent cases: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