UK corporate offence of failure to prevent tax evasion
A bite-sized summary of recent UK pension news Welcome to our latest update, in which we cover: Pensions dashboards blog: connecting via a third party Explaining the key steps when connecting to the dashboards ecosystem...more
Sonder Europe Limited (Sonder) leased self-contained apartments from landlords for 2 to 10 years, furnishing and decorating them if needed (without altering the fabric or structure of the apartment), and then sub-let them to...more
On January 17, 2025, the UK Court of Appeal (Court) released its decision on whether certain members of BlueCrest Capital Management (UK) LLP (BlueCrest) should be taxed as employees under the UK “salaried members” rules (the...more
The Court of Appeal has taken an unexpectedly narrow and unfavourable interpretation of the significant influence test (Condition B) of the LLP salaried member rules in HMRC v Bluecrest Capital Management (UK) LLP. The...more
The Court of Appeal has remitted the case of BlueCrest Capital Management (UK) LLP (BlueCrest) v HMRC back to the First-tier Tribunal (FTT) regarding the application of the UK’s salaried members rules (the Rules) to certain...more
Welcome to the September 2024 edition of our UK Tax Round Up. This month has seen decisions on UK tax residence, VAT group eligibility and the Supreme Court’s ruling in the long running case involving the employment status of...more
Welcome to the June edition of the UK Tax Round Up. This month features the latest Court of Appeal decision in a trilogy of recent cases regarding the loan relationship “unallowable purpose” test, an Upper Tribunal decision...more
Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more
Welcome to your weekly update from the Allen & Overy Pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions. This week we cover the following topics: HMRC lifetime...more
Welcome to December’s edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income, the latest instalment in the BlueCrest partner...more
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
Asset managers established as LLPs will welcome the Upper Tribunal’s recent decision to uphold the decision of the First Tier Tax Tribunal (“FTT”) on the application of the salaried member rules in Bluecrest...more
The Upper Tribunal (UT) has upheld the decision of the First‑tier Tribunal (FTT) regarding the application of the UK’s salaried member rules (the Rules) to certain members of BlueCrest Capital Management (UK) LLP (BlueCrest),...more
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
Under section 213 Insolvency Act 1986, liquidators may bring claims against third parties suspected of being a party to fraud, even where they were not involved in the management or control of the insolvent company. The...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
Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more
Settlement agreements are a pragmatic and effective tool in resolving workplace disputes. The employee benefits from financial support and a dignified exit, and the employer achieves a clean break. However, when used...more
Welcome to the August edition of the UK Tax Round Up. August turned out to be not such a quiet month on the UK tax front. We have seen several important and technical case law decisions, some of which we discuss below, and...more
Everybody loves a list at this time of year. With the end of year fast approaching, everyone is working through their gift lists, to-do lists and grocery lists for their holiday celebrations. For the 12 Days of Christmas,...more
Battle Royal – handling of boardroom dispute was repudiatory breach - The High Court decision in Stobart Group Ltd v Tinkler explores the extent of a director's duties in the context of a boardroom dispute....more
UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more
In its July 1, 2015 decision in the case of Anson v. HM Revenue & Customs (2015 UKSC 44), the Supreme Court of England and Wales ruled that a Delaware limited liability company was “transparent” for UK income tax purposes. A...more