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
In 2027, the UK will introduce a carbon border adjustment mechanism (CBAM) on imports of certain carbon intensive goods. The CBAM will impose a charge on the emissions embodied in relevant imports that take place on or after...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
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
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
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
Following the European Court of Justice’s (ECJ) rulings in Meo and Vodafone Portugal, HMRC has recently updated its VAT manual and published a brief...more
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
Temporary changes to the statutory residence test for inbound COVID-19 workers - The UK Chancellor has written to the chair of the Treasury Select Committee outlining temporary changes to the statutory residence test...more
UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more
UK Case Law Developments - More decisions on IR35 - This month has seen two more decisions on whether broadcast presenters providing their services to the BBC and ITV respectively would or would not have been...more
UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more
Case Law Developments - Place of supply for VAT purposes - The recent case of American Express Services Europe Limited (AESEL) v HMRC is a useful reminder of the well-established two-stage approach to determining the...more
UK Case Law Developments - Valid notice crucial to tax indemnity claim - The Court of Appeal (CA) decision in Stobart Group Ltd v Stobart and another is a cautionary tale for any purchaser who, following the...more
On 13 March 2019 the UK government published details of the temporary rates of customs duty it would impose on imports should a "no deal" Brexit occur. Under the temporary regime, the government expects 87% of total imports...more
UK Developments - Taxpayer succeeds in judicial review case against HMRC - On 22 November 2018, the Upper Tribunal published its decision on the judicial review case of R. (on the application of Vacation Rentals (UK)...more
HM Revenue and Customs (HMRC) has issued a letter to 145,000 UK businesses setting out actions they need to take now to prepare for the “unlikely event of the UK leaving the EU without a deal.” More substantial steps may be...more
General UK Tax Developments - CIOT responds to the draft profit fragmentation provisions in the Finance Bill 2019 - The Chartered Institute of Taxation (CIOT) has published its response to the profit fragmentation...more
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
VAT treatment of supplies of non-employed temps clarified - A recent Court of Appeal case – Adecco v HMRC – clarifies a longstanding question over seemingly contradictory case law on the VAT treatment of employment agency...more
General UK Tax Developments - Enterprise management incentive (EMI) options State Aid approval - We referred in the April UK Tax Round Up to the expiry of the EU's State Aid approval for EMI options. Fortunately, this...more
General UK tax developments - Changes to taxation of termination payments - HMRC has updated its Employment Income Manual to reflect the changes to the taxation of termination payments (including payments in lieu of...more
Case law developments - Settlement payment not deductible as an expense of a trade (Vaines v HMRC) - Mr. Vaines was a solicitor. In the 2007/08 tax year he paid a settlement amount to a third party that had made a...more
The European Union has published a technical note warning of dire consequences for businesses if the UK leaves the EU with no deal in place. The European Commission has warned companies across Europe to prepare for...more
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