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Notable Cases

The members of Cannon Chambers relish representing their clients in the courts and tribunals and fighting their client’s corner whenever mediation is unsuccessful or a settlement is not possible. The following selection of their recent cases gives you a flavour of their work as advocates.

MAS Fabrics Hong Kong Limited v HMRC [2021]

Patrick Cannon represented the taxpayer company in this penalty appeal and the decision reveals the difficulty that taxpayers may sometimes experience when relying on their professional adviser to argue that they took reasonable care when relief from the 15% rate of SDLT is mistakenly claimed. Read the full decision here.…

HYMAN, PENSFOLD AND GOODFELLOW V HMRC [2021]

In this appeal, Cannon Chambers represented the taxpayers in their appeal to the Upper Tribunal which argued that their property purchases should have been classified as of mixed residential and non-residential land and so should have been liable to the lower rates of SDLT in Table B.’ We relied on…

PAUL AND JANE WILKINSON V HMRC [2021]

In this appeal, I represented the taxpayers Paul and Jane Wilkinson in their appeal against HMRC’s refusal to allow a claim for multiple-dwellings relief from SDLT. The decision contains detailed comment and analysis from Judge Bowler on the application of the definition of “dwelling” for MDR to the detailed facts…

ANDREW AND TIFFANY DOE V HMRC [2021]

This appeal, in which I represented the taxpayers, concerned the date from which the nine-month enquiry period starts to run when an amended return is filed and also the definition of a dwelling for multiple dwellings relief purposes in the context of the main house with an annex within the…

LEISURE PARKS REAL ESTATE LIMITED V HMRC [2021]

This appeal concerned penalties levied by HMRC on a company for the late filing of its corporation tax return. Patrick Cannon appeared for the company against HMRC. The case is interesting because HMRC had reduced the penalties to nil for a sister company which had also filed its returns late…

MICHAEL BENTLEY V HMRC [2021]

This appeal involved Follower Notices and penalties for failing to take corrective action following the receipt by the taxpayer of follower notices from HMRC. After a fairly extensive examination of the taxpayer by Patrick Cannon and cross-examination by HMRC, Patrick persuaded the tax tribunal to allow a substantial reduction in…

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