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United Kingdom Tax Court

Cadwalader, Wickersham & Taft LLP

Asset Disposals in the "Real World"

The recent case of A Sajedi and others v HMRC [2025] UKFTT 297 (TC) in the UK First-tier Tribunal (“FTT”) is an interesting example of a UK taxation tribunal intervening to decide a litigated matter on grounds that neither...more

Hogan Lovells

Tax relief for predevelopment costs

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In a case that will be of interest to all developers and funders of UK infrastructure and energy projects, Orsted West of Duddon Sands v HMRC [2025] (previously known as Gunfleet Sands v HMRC), the Court of Appeal held that...more

Proskauer - Tax Talks

BlueCrest – the Court of Appeal considers Condition B of the salaried members rules

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The Court of Appeal has remitted the case of BlueCrest Capital Management (UK) LLP (BlueCrest) v HMRC back to the First-tier Tribunal (FTT) regarding the application of the UK’s salaried members rules (the Rules) to certain...more

Cadwalader, Wickersham & Taft LLP

“Ephemeral” Payments and Beneficial Entitlement

Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises.  The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more

Cadwalader, Wickersham & Taft LLP

Court of Justice Rules on UK Group Asset Transfer Rules

The UK tax legislation imposes an “exit tax charge” on the unrealised capital gains of a company which migrates from the UK. The exit of a taxpayer (or their assets) is generally the last point in which a taxing jurisdiction...more

Cadwalader, Wickersham & Taft LLP

HMRC v BlackRock Holdco 5 LLC Throws a Spotlight on UK Transfer Pricing and the ‘Unallowable Purposes’ Rule

A decision in late-July 2022 of the UK’s Upper-tier Tax tribunal (“UTT”) has held that interest recognized by a UK resident company on loan notes issued to its parent was non-deductible under the UK transfer pricing rules, as...more

Proskauer Rose LLP

UK Tax Round Up - May 2022

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Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

Proskauer Rose LLP

UK Tax Round Up - March 2022

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Welcome to the March edition of the Proskauer UK Tax Round Up. In his Spring Statement, the Chancellor focused on measures to alleviate the increasing cost of living and to boost investment in the economy but there were no...more

Proskauer Rose LLP

UK Tax Round Up - January 2022

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UK Case Law Developments - Contributions to remuneration trust scheme not tax deductible - In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more

Proskauer Rose LLP

UK Tax Round Up - December 2021

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UK Case Law Developments - Taxpayer treated as receiving distribution in tax avoidance case - We reported on First-tier Tribunal’s (FTT’s) decision in Dunsby v Revenue & Customs in our June 2020 UK Tax Round Up. By way...more

Latham & Watkins LLP

Recent Developments in the W&I Insurance Market

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Increased competition among insurers and improved policy terms suggest the W&I insurance market is becoming more favourable to investors. In real estate transactions, buyers and sellers naturally pursue conflicting...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

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