UK corporate offence of failure to prevent tax evasion
Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....more
The Upper tax tribunal (“Upper Tribunal”) has confirmed the decision of the First-tier tax tribunal (“FTT”), delivered in 2021, in the case of Kwik-Fit Group Limited and others v HMRC. This decision of the Upper Tribunal...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
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
UK Case Law Developments - Entrepreneurs' relief – voting rights not imputed for equitable reasons - In George v HMRC, the First Tier Tribunal (FTT) decided that they could not apply the equitable principle that...more
The impact of discounts on consideration for VAT purposes (Finanzamt Bingen-Alzey v Boehringer Ingelheim Pharma GmbH & Co. KG) - The ECJ has confirmed that consideration for VAT purposes should be reduced by any discount...more