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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 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

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

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

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

Burgess v HM Revenue & Customs/Brimheath Developments Ltd v HM Revenue & Customs [2015]

In the recent case of Burgess v HM Revenue and Customs [2015] the Upper Tribunal (UT) considered what HMRC needs to prove in order for a discovery assessment raised by it on a taxpayer to be valid.
11 December 2015

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

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

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
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