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Income Taxes Tax Tribunal United Kingdom

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Cadwalader, Wickersham & Taft LLP

“Ephemeral” Payments and Beneficial Entitlement

Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises.  The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more

Proskauer - Tax Talks

Court of Appeal decides that Jersey companies were UK tax resident

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In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the...more

Proskauer - Tax Talks

Advisers’ fees non-deductible where management decisions made by parent company

Proskauer - Tax Talks on

The UK’s First-tier tax tribunal (FTT) has just released an interesting decision considering whether or not expenses incurred by a parent company on advisers’ fees that related to a proposed disposal by a group subsidiary and...more

Dechert LLP

Financial Services Quarterly Report - Third Quarter 2019: Developments in the UK Tax Treatment of Fee Rebates and Trail...

Dechert LLP on

UK investment managers paying fee rebates, loyalty bonuses or similar payments to UK investors and certain non-UK investors in collective investment schemes should note recent case law developments regarding the tax treatment...more

Proskauer Rose LLP

UK Tax Round Up - September 2018

Proskauer Rose LLP on

UK Case Law Developments - Entrepreneurs' relief – voting rights not imputed for equitable reasons - In George v HMRC, the First Tier Tribunal (FTT) decided that they could not apply the equitable principle that...more

Proskauer Rose LLP

UK Tax Round Up - January 2018

Proskauer Rose LLP on

The impact of discounts on consideration for VAT purposes (Finanzamt Bingen-Alzey v Boehringer Ingelheim Pharma GmbH & Co. KG) - The ECJ has confirmed that consideration for VAT purposes should be reduced by any discount...more

Dechert LLP

HMRC Publishes Guidance on the Tax Treatment of Clawback of Remuneration in the UK

Dechert LLP on

Since the financial crisis of 2008 / 2009, swathes of new regulations have been introduced governing various aspects of remuneration in the financial services sector. A key feature of these rules is the compulsory clawback of...more

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