Speed read: In Hargreaves v HMRC, the First-tier Tribunal (FTT) allowed Hargreaves’ appeal against a discovery assessment that was ‘stale’, with HMRC losing out on £84m of tax. In Atholl House Productions Ltd v HMRC, HMRC lost another IR35 case against a TV presenter. In Hull City AFC (Tigers) Ltd v HMRC, the FTT held that payments made to Geovanni Gomez’s offshore company under an image rights contract were taxable employment income, rather than consideration for the licensing of his image rights. In Warshaw, the FTT held that cumulative preference shares constituted ordinary share capital such that CGT entrepreneurs’ relief applied.
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