The Supreme Court has delivered its judgment in Centrica Overseas Holdings. Kyle O’Sullivan (BCLP) reviews the case and its implications.
True story: on the morning of 18 November 2022 I was asked by a client to advise on the potential deductibility of certain transaction fees incurred in respect of a subsidiary which they had sold. After giving my thoughts I had to ring them back later that evening to revise my advice as the Court of Appeal had earlier that day delivered its judgment in HMRC v Centrica Overseas Holdings Ltd [2022] EWCA Civ 1520 overturning the Upper Tribunal’s decision ([2021] UKUT 200 (TCC)) upon which I had heavily relied!
There would have been no repeat scenario on 16 July 2024 when the Supreme Court delivered its judgment on the appeal ([2024] UKSC 25) agreeing with the Court of Appeal and finding unanimously...
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The Supreme Court has delivered its judgment in Centrica Overseas Holdings. Kyle O’Sullivan (BCLP) reviews the case and its implications.
True story: on the morning of 18 November 2022 I was asked by a client to advise on the potential deductibility of certain transaction fees incurred in respect of a subsidiary which they had sold. After giving my thoughts I had to ring them back later that evening to revise my advice as the Court of Appeal had earlier that day delivered its judgment in HMRC v Centrica Overseas Holdings Ltd [2022] EWCA Civ 1520 overturning the Upper Tribunal’s decision ([2021] UKUT 200 (TCC)) upon which I had heavily relied!
There would have been no repeat scenario on 16 July 2024 when the Supreme Court delivered its judgment on the appeal ([2024] UKSC 25) agreeing with the Court of Appeal and finding unanimously...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
