In this podcast, Zoe Andrews and Tanja Velling discuss the First-tier Tribunal’s decision in Blackfriars Hotel applying an anti-avoidance provision in the loss relief regime to a loss-refreshing transaction reminiscent of the Kwik-Fit unallowable purpose case.
They also discuss the First-tier Tribunal’s decision in Grint on the sale of occupational income rules (which had been used by HMRC as an alternative argument in the BlueCrest, HFFX and BCG  partnership remuneration cases) and the Court of Appeal’s decision in Refinitiv, a judicial review case concerning the compatibility of diverted profits tax notices with a prior advance pricing agreement.
They are then joined by Tax Associate Kasim Mehmood for a discussion of the Supreme Court’s approach to interpreting tax legislation in Cobalt Data Centre and changes to HMRC’s capital gains manual in respect of the reorganisation rules.
The podcast also covers PISCES, a proposed new type of regulated trading platform for private shares, and what 2025 might bring in terms of UK, EU and US tax developments, including (in case of the UK) various consultations on changes to the transfer pricing rules as well as potential enquiry activity in this area.

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