In Claims Advisory Group v HMRC,
The Upper Tribunal (UT) has confirmed that the service of claiming compensation on behalf of third parties for mis-sold payment protection insurance (PPI), is subject to VAT and not exempt...more
In Haworth v HMRC the Supreme Court (SC) upheld the Court of Appeal’s (CA’s) decision to quash a follower notice (FN) and accelerated payment notice (APN) issued to the taxpayer, Mr Haworth. An FN can be issued by HMRC where...more
8/2/2021
/ Accelerated Payments ,
Bonuses ,
Charitable Trusts ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
NICS ,
OECD ,
Preferred Shares ,
Proposed Legislation ,
Regulatory Agenda ,
Remuneration ,
Tax Avoidance ,
Tax Reform ,
UK ,
Valuation ,
Value-Added Tax (VAT)
UK Case Law Developments -
Income tax consequences of pension-related payments in E.ON v HMRC -
E.ON v HMRC concerned a large UK power and gas supplier, which paid certain lump sum payments, called “facilitation...more
7/6/2021
/ Corporate Taxes ,
Double Taxation ,
Employee Benefits ,
HMRC ,
Income Taxes ,
International Tax Issues ,
OECD ,
Pension Schemes ,
Pensions ,
Tax Avoidance ,
UK
UK General Tax Developments -
Stamp Duty and COVID-19 -
Since the start of the first UK lockdown in March 2020, HMRC has been accepting that documents can be stamped electronically. HMRC has now confirmed that, where...more
UK Case Law Developments -
Tax avoidance motive did not prevent availability of share for share exchange treatment -
In Euromoney Institutional Investor plc v HMRC, the FTT held that the share for share exchange...more
This was an appeal against the High Court decision in Dodika Ltd & Ors v United Luck Group Holdings Limited from August 2020 (see our Tax Blog on this). The case concerns the question of whether the notice given by the buyer...more
Spring Budget and Tax Day -
After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more
UK Case Law Developments -
EIS relief not available for shares carrying preferential rights -
The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more
3/10/2021
/ Corporate Taxes ,
EU ,
European Commission ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
OECD ,
Private Equity ,
Tax Avoidance ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
Extension of support for retail, leisure and hospitality businesses -
Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
2/8/2021
/ Anti-Avoidance ,
Capital Gains ,
Capital Gains Tax ,
Coronavirus/COVID-19 ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Job Retention Schemes ,
Partnerships ,
Tax Avoidance ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
From the beginning of the UK’s first lockdown in March of last year we have reported on the impact of the pandemic on individual and corporate tax residence and permanent establishment risk.
In April 2020 the OECD...more
COVID-19 Developments -
Tax exemptions for coronavirus antigen costs -
Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more
1/5/2021
/ Corporate Taxes ,
HM Treasury ,
HMRC ,
Holding Companies ,
Income Taxes ,
International Tax Issues ,
OECD ,
Private Equity ,
Tax Planning ,
Transfer Pricing ,
UK ,
Value-Added Tax (VAT)
On 30 December, the UK government laid regulations that will significantly reduce the type of cross-border arrangement that will need to be reported by UK intermediaries under the so-called DAC 6 rules on 31 January 2021 and...more
In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the...more
UK COVID-19 Developments -
Extension of support for employed and self-employed workers -
On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more
12/3/2020
/ Capital Gains Tax ,
Corporate Taxes ,
EU ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Job Retention Schemes ,
Tax Avoidance ,
Tax Exemptions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
The Office of Tax Simplification (OTS) has published its first report following its review of certain aspects of the UK’s capital gains tax regime requested by the Chancellor in July this year with the specific purpose of...more
UK COVID-19 Developments -
UK Prime Minister’s statement on COVID-19 -
On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more
11/9/2020
/ BEPS ,
Corporate Taxes ,
European Commission ,
Fund Managers ,
HMRC ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
OECD ,
OTS ,
Pension Schemes ,
Tax Authority ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
Budget Cancelled -
The Government announced on 23rd September that the Budget scheduled for November would, as a result of the ongoing Covid-19 pandemic, now not take place....more
9/29/2020
/ Anti-Abuse Rule ,
European Court of Justice (ECJ) ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Research and Development ,
Tax Relief ,
UK ,
UK Insolvency Act ,
Value-Added Tax (VAT)
HMRC has updated its guidance on the Coronavirus Job Retention Scheme (CJRS). The changes include the removal of parts of the guidance that related to the application of the CJRS up to 30 June 2020 and to update employers on...more
In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not...more
8/14/2020
/ Buyers ,
Corporate Taxes ,
International Tax Issues ,
Notice Provisions ,
Private Equity ,
Sellers ,
Share Purchase Agreements ,
Tax Liability ,
Tax Planning ,
Transfer Pricing ,
UK
UK COVID-19 Developments -
Furlough not detrimental to EMI options held on 19 March 2020 -
On 26 June, the government introduced a new provision into the Finance Bill that provides that the period during which an...more
8/5/2020
/ Capital Gains Tax ,
Coronavirus/COVID-19 ,
Employee Retention ,
Employment Tax ,
Furloughs ,
Future Fund ,
HMRC ,
International Tax Issues ,
Limited Liability Partnerships ,
Maternity Leave ,
National Insurance Contributions ,
Startups ,
State Aid ,
Tax Avoidance ,
UK ,
Value-Added Tax (VAT) ,
Working Time Regulations
As the UK’s lockdown is relaxed and unemployment figures are expected to continue to rise, the UK Chancellor gave his summer statement announcing measures to stimulate the economy as it recovers from the effects of...more
7/10/2020
/ Coronavirus/COVID-19 ,
Crisis Management ,
Economic Downturn ,
Global Market ,
Hospitality Industry ,
Infectious Diseases ,
International Tax Issues ,
Restaurant Industry ,
Retail Market ,
Tourism ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
HMRC updates its trading activities guidance -
HMRC has updated its guidance at BIM48000 regarding how legislation and case law should be applied where a business makes changes to its...more
7/1/2020
/ Corporate Taxes ,
Cross-Border Transactions ,
Guidance Update ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Loan Market Association ,
Reporting Requirements ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 developments -
Proposed deferral of DAC6 and DAC2 -
The European Commission has published a draft directive proposing a three month delay to the deadlines for certain information disclosures under the EU...more
6/3/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
EU ,
European Commission ,
HMRC ,
Income Taxes ,
Infectious Diseases ,
International Tax Issues ,
Personal Protective Equipment ,
Tax Deductions ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
There has been much discussion over the past year or so about the UK government’s proposal to make changes to the application of the off-payroll working (or IR35) tax rules to private sector end clients so as to shift certain...more
The UK’s First-tier tax tribunal (FTT) has just released an interesting decision considering whether or not expenses incurred by a parent company on advisers’ fees that related to a proposed disposal by a group subsidiary and...more