Nigel Doran (Macfarlanes) examines the recent decision in HMRC v Smith & Williamson Corporate Services on the taxation of payments in connection with the transfer of client connection to another business.
HMRC v Smith & Williamson Corporate Services Ltd [2015] UKUT 666 (reported in Tax Journal 8 January 2016) is the latest in a line of cases which have endeavoured not always consistently to clarify how tax law applies to payments in connection with the transfer of client connection to a business eager to acquire it.
The facts
Between 1996 and 2004 Patrick Smiley and a team of individuals that he led (‘the team’) carried on the business of investment fund management not on their own account but as employees first of Panmure Gordon and then of Butterfield. In that...
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Nigel Doran (Macfarlanes) examines the recent decision in HMRC v Smith & Williamson Corporate Services on the taxation of payments in connection with the transfer of client connection to another business.
HMRC v Smith & Williamson Corporate Services Ltd [2015] UKUT 666 (reported in Tax Journal 8 January 2016) is the latest in a line of cases which have endeavoured not always consistently to clarify how tax law applies to payments in connection with the transfer of client connection to a business eager to acquire it.
The facts
Between 1996 and 2004 Patrick Smiley and a team of individuals that he led (‘the team’) carried on the business of investment fund management not on their own account but as employees first of Panmure Gordon and then of Butterfield. In that...
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:
