Welcome to the October edition of the UK Tax Round Up. This month has seen the Supreme Court’s judgment on the operation of the employment-related securities deeming provision, the Court of Appeal’s decision on what...more
11/6/2023
/ Appeals ,
Business Succession ,
Cayman Islands ,
Court of Justice of the European Union (CJEU) ,
Debt ,
Draft Guidance ,
EU ,
Hedge Funds ,
HMRC ,
Loan Repayment Issues ,
Partnership Agreements ,
Pensions ,
Securities ,
UK ,
Value-Added Tax (VAT)
Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting cases highlighting the need for taxpayers and HMRC alike to apply a realistic approach to the facts in assessing the tax...more
Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more
3/29/2023
/ Beneficial Owner ,
Capital Gains ,
Corporate Taxes ,
Double Taxation ,
HMRC ,
Income Taxes ,
Interest Rates ,
OECD ,
Offshore Funds ,
Private Funds ,
Securities ,
Tax Relief ,
Taxation ,
Value-Added Tax (VAT)
Welcome to February’s edition of our UK Tax Round Up. The month has seen interesting cases on the “entitlement” to income and the single and multiple supply tests for VAT as well as announcement of the publication date for...more
VAT incurred on corporate advisory fees not recoverable -
In Ince Gordon Dadds LLP v HMRC, the First-tier Tribunal (FTT) has decided that Ince Gordon Dadds LLP (formerly Culver Holdings Limited and the taxpayer) (Culver)...more
2/1/2023
/ Acquisitions ,
Annotated Case Law ,
Appeals ,
Court of Justice of the European Union (CJEU) ,
GAAP ,
HMRC ,
International Tax Issues ,
OECD ,
Personal Services ,
Research and Development ,
UK ,
Value-Added Tax (VAT)
Welcome to the October edition of the UK Tax Round Up. October has been an extraordinary month in the UK, with political turbulence triggering reversals of many of the tax policies announced by the government at the end of...more
11/1/2022
/ Double Taxation ,
EU ,
European Court of Justice (ECJ) ,
HMRC ,
Income Taxes ,
Interest Rate Adjustments ,
Reversal ,
Tax Liability ,
Tax Policy ,
UK ,
Value-Added Tax (VAT)
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
6/8/2022
/ Advocate General ,
Corporate Taxes ,
EU ,
Income Taxes ,
International Tax Issues ,
OECD ,
Remuneration ,
Tax Code ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Reform ,
Transfer of Assets ,
UK ,
Value-Added Tax (VAT)
Welcome to February’s edition of our UK Tax Round Up. This month’s edition includes updated guidance on the VAT treatment of contractual termination payments, updated HMRC guidance on the assessment of “substantial”...more
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
2/10/2022
/ Business Losses ,
EU ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Tax Code ,
Tax Court ,
Tax Deductions ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
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
1/5/2022
/ Distribution Rules ,
Dividend-Equivalent Transactions ,
International Tax Issues ,
Legal Costs ,
Proposed Regulation ,
Regulatory Agenda ,
Share Class Structures ,
Stock Options ,
Tax Avoidance ,
Tax Code ,
Tax Court ,
Tax Liability ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
In Claims Advisory Group v HMRC,
The Upper Tribunal (UT) has confirmed that the service of claiming compensation on behalf of third parties for mis-sold payment protection insurance (PPI), is subject to VAT and not exempt...more
In Haworth v HMRC the Supreme Court (SC) upheld the Court of Appeal’s (CA’s) decision to quash a follower notice (FN) and accelerated payment notice (APN) issued to the taxpayer, Mr Haworth. An FN can be issued by HMRC where...more
8/2/2021
/ Accelerated Payments ,
Bonuses ,
Charitable Trusts ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
NICS ,
OECD ,
Preferred Shares ,
Proposed Legislation ,
Regulatory Agenda ,
Remuneration ,
Tax Avoidance ,
Tax Reform ,
UK ,
Valuation ,
Value-Added Tax (VAT)
UK General Tax Developments -
Stamp Duty and COVID-19 -
Since the start of the first UK lockdown in March 2020, HMRC has been accepting that documents can be stamped electronically. HMRC has now confirmed that, where...more
UK Case Law Developments -
Tax avoidance motive did not prevent availability of share for share exchange treatment -
In Euromoney Institutional Investor plc v HMRC, the FTT held that the share for share exchange...more
Spring Budget and Tax Day -
After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more
UK Case Law Developments -
EIS relief not available for shares carrying preferential rights -
The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more
3/10/2021
/ Corporate Taxes ,
EU ,
European Commission ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
OECD ,
Private Equity ,
Tax Avoidance ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
Extension of support for retail, leisure and hospitality businesses -
Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
2/8/2021
/ Anti-Avoidance ,
Capital Gains ,
Capital Gains Tax ,
Coronavirus/COVID-19 ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Job Retention Schemes ,
Partnerships ,
Tax Avoidance ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
COVID-19 Developments -
Tax exemptions for coronavirus antigen costs -
Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more
1/5/2021
/ Corporate Taxes ,
HM Treasury ,
HMRC ,
Holding Companies ,
Income Taxes ,
International Tax Issues ,
OECD ,
Private Equity ,
Tax Planning ,
Transfer Pricing ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
Extension of support for employed and self-employed workers -
On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more
12/3/2020
/ Capital Gains Tax ,
Corporate Taxes ,
EU ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Job Retention Schemes ,
Tax Avoidance ,
Tax Exemptions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
UK Prime Minister’s statement on COVID-19 -
On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more
11/9/2020
/ BEPS ,
Corporate Taxes ,
European Commission ,
Fund Managers ,
HMRC ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
OECD ,
OTS ,
Pension Schemes ,
Tax Authority ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
Budget Cancelled -
The Government announced on 23rd September that the Budget scheduled for November would, as a result of the ongoing Covid-19 pandemic, now not take place....more
9/29/2020
/ Anti-Abuse Rule ,
European Court of Justice (ECJ) ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Research and Development ,
Tax Relief ,
UK ,
UK Insolvency Act ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
Furlough not detrimental to EMI options held on 19 March 2020 -
On 26 June, the government introduced a new provision into the Finance Bill that provides that the period during which an...more
8/5/2020
/ Capital Gains Tax ,
Coronavirus/COVID-19 ,
Employee Retention ,
Employment Tax ,
Furloughs ,
Future Fund ,
HMRC ,
International Tax Issues ,
Limited Liability Partnerships ,
Maternity Leave ,
National Insurance Contributions ,
Startups ,
State Aid ,
Tax Avoidance ,
UK ,
Value-Added Tax (VAT) ,
Working Time Regulations
As the UK’s lockdown is relaxed and unemployment figures are expected to continue to rise, the UK Chancellor gave his summer statement announcing measures to stimulate the economy as it recovers from the effects of...more
7/10/2020
/ Coronavirus/COVID-19 ,
Crisis Management ,
Economic Downturn ,
Global Market ,
Hospitality Industry ,
Infectious Diseases ,
International Tax Issues ,
Restaurant Industry ,
Retail Market ,
Tourism ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
HMRC updates its trading activities guidance -
HMRC has updated its guidance at BIM48000 regarding how legislation and case law should be applied where a business makes changes to its...more
7/1/2020
/ Corporate Taxes ,
Cross-Border Transactions ,
Guidance Update ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Loan Market Association ,
Reporting Requirements ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 developments -
Proposed deferral of DAC6 and DAC2 -
The European Commission has published a draft directive proposing a three month delay to the deadlines for certain information disclosures under the EU...more
6/3/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
EU ,
European Commission ,
HMRC ,
Income Taxes ,
Infectious Diseases ,
International Tax Issues ,
Personal Protective Equipment ,
Tax Deductions ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)