Canadian Solar EMEA GmbH v HMRC [2025]: A Warning on Cross-Border Classifications and Duty Liability

In a landmark decision handed down by the Upper Tribunal in 2025, the case of Canadian Solar EMEA GmbH v HMRC brought renewed attention to the importance of product classification and origin rules in cross-border trade. While the decision focused on the importation of solar panels, its implications go far beyond one sector. At the […]

Rettig Heating Group UK Ltd v HMRC [2025]: Substance Over Form Reaffirmed in Corporate Tax Planning

In the 2025 Upper Tribunal decision Rettig Heating Group UK Ltd v HMRC, the court tackled the tax treatment of complex intra-group transactions carried out by Rettig Heating Group UK Ltd. This judgment sheds light on how UK tax law approaches the distinction between the legal form and the commercial substance of corporate arrangements, particularly […]