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Publication

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

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

Publication

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

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

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
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