• Scambler & Scambler v Commissioner for Her Majesty’s Revenue & Customs [2016] UKFTT 47 (TC)

    Income Tax Act 2007, ss.67 & 68 – Sideways loss relief – ‘Reasonable expectation of profits’ test: s.68(3) – Onus of proof of reasonableness of expectation of no profit – Evidence to be provided by taxpayer

  • Lynch v Revenue and Customs Commissioner [2025] UKFTT 300 (TC)

    Income Tax – Ramsay doctrine and s381 ITTOIA 2005 – profit income or capital – procedural
    validity of discovery assessment – s29(5) TMA test – distinct parts of an insufficiency of tax –
    Human Rights and High Income Child Benefit Charge – Appeal dismissed