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Telefonica v HMRC: When HMRC has a duty to consult a taxpayer

When HMRC challenged how Telefonica agreed they calculate VAT phone charges, Telefonica appealed and the Tribunal found they had not been given clear assurance so the judicial review appeal failed.
10 May 2016

HMRC v Castledine: A useful guide to statutory interpretation

Claiming Entrepreneur’s Relief on a share disposal with the required 5% company shareholding failed when the Tribunal found they were considered ordinary shares so the taxpayer only owned 4.99%.
10 May 2016


Tax changes for individual shareholders receiving a distribution in a liquidation

Tax treatment for individual shareholders receiving a distribution from a members' voluntary liquidation may be affected by changes applying (retrospectively) from 6 April 2016.
03 May 2016

HMRC v Trigg – to QCB or not to QCB?

Would a change in currency in the UK or if the UK were to become an EU Member State be enough to make Qualifying Corporate Bonds into non-Qualifying Corporate Bonds?
27 April 2016

Blue Yearnings Limited – case summary

The Blue Yearnings case is, in many ways, unremarkable. However, it serves as a timely reminder to make sure that everyone is clear as to who owns the asset.
08 April 2016

Moorthy v Revenue & Customs Commissioners (2016) – How to tax age discrimination awards?

In this recent case, the Upper Tribunal (“UT”) provided guidance on the taxation of awards for "injury to feelings" paid in respect of the termination of employment.
29 March 2016

Julian Nott v Commissioners for HMRC [2016] – trading or property income?

Property income and trading income are taxed under different provisions of the tax code. This can sometimes have practical implications for the taxpayer.
16 March 2016

Easinghall Ltd v HMRC

In the case of Easinghall Ltd v Revenue and Customs Commissioners, the exact question that was being asked was crucial.
16 March 2016

What makes cross-border VAT arrangements abusive?

This recent case provides guidance on when cross-border VAT arrangements will be considered "abusive".
02 February 2016


Could you use EIS to attract investment?

The Enterprise Investment Scheme has evolved continually since inception. Recent years saw great increases in applicable thresholds, creating greater incentive for investors to make investments.
29 January 2016

Flix Innovations Ltd v HMRC: EIS conditions strictly applied

The Enterprise Investment Scheme (EIS) can provide very significant tax relief for investors in unlisted companies but a recent case shows how strictly the rules of the Scheme are interpreted.
05 January 2016

French Education Property Trust Limited v HMRC: VAT on building independent schools

This case in the First-Tier Tribunal concerned whether the letting of school premises to an independent school and the running of this school were business purposes under VAT law.
05 January 2016
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