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Publication

Anson v HMRC: HMRC's response to Supreme Court decision on Double Tax Treaty Relief

HMRC responds to the Supreme Court's decision in Anson v HMRC Commissioners that an individual taxpayer can claim double tax treaty relief on his share of profits in a limited liability company.
27 November 2015

Publication

Court of Justice of the European Union: Bitcoin exchanges

This briefing discusses the Court of Justice of the European Union's ruling in Skatteverket v David Hedqvist C-264/14 concerning currency exchange for 'Bitcoin' or vice versa (exempt from VAT).
26 November 2015

When no profit IS a profit: GDF Suez v Teeside [2015] UKFTT 0413 (TC)

A recent First-Tier Tribunal case demonstrates that accounts, prepared in accordance with UK GAAP, do not always reflect companies profits for tax purposes.
15 September 2015

£17.5m payment to remove restrictions on selling shares not deductible for CGT

In a recent case, HMRC was successful in arguing that a payment made by a taxpayer to remove restrictions on his right to sell shares could not be deducted from his gains on selling those shares.
15 September 2015

Anson v HMRC: UK Taxpayer win: Double Tax Treaty Relief in Respect of Profits from US LLC

The Supreme Court has held in Anson v HMRC Commissioners that an individual taxpayer was entitled to double tax treaty relief in respect of his share of profits in a Delaware LLC.
11 August 2015

Economic reality and the supply of services: looking behind the engagement letter

The Tribunal has upheld HMRC's decision that a company (Danesmoor Ltd) should not be entitled to recover input VAT incurred on professional fees for a corporate restructuring.
10 August 2015

Enterprise Investment Scheme: don’t expect Human Rights support, be sure to make a claim

The First Tier Tribunal found that a taxpayer who did not claim EIS income tax relief exemption was consequently unable later to claim the much more valuable CGT exemption when his shares were sold.
15 July 2015

Discrimination settlement did not amount to employment earnings

An employer's payment to an ex-employee pursuant to a compromise agreement, in full and final settlement of a potential race discrimination claim, does not amount to taxable earnings.
01 July 2015

Film schemes flop following HMRC review: Samarkand case 2015

In Samarkand Film Partnership No 3 and others v Revenue and Customs Commissioners, the Upper Tribunal (UT) delivered a decision in favour of HMRC to deny tax relief for partnership losses .
01 July 2015

Publication

Challenging Accelerated Payment Notices

The High Court has refused to order injunctions preventing HMRC from issuing accelerated payment notices or enforcing existing APNs.
22 May 2015

How systematic is systematic? HMRC unable to answer FOI request on the Lagarde List

Following HMRC's press release regarding its use of the Lagarde List to 'assess, collect enforce and prosecute tax offences', Burges Salmon made a Freedom of Information request.
20 May 2015

FTT rules in favour of taxpayer: succession losses can be offset against profits

The First Tier Tribunal has found that that a taxpayer that succeeded to a trade was entitled to set carried-forward pre-succession losses against all of its trading profits.
08 May 2015
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