Two recent decisions have sought to clarify the extent to which the EU freedom of establishment and of the movement of capital were restricted in light of various UK legislative provisions dealing with cross-border transactions and/or operations, as Dominic Stuttaford and Greg Branagan (Norton Rose Fulbright) explain.
Buried among the flurry of activity leading up to the end of the Brexit transitional period on 31 December 2020 were two judgments by the First-tier Tribunal (FTT) and Upper Tribunal (UT) (respectively) relating to the interrelation between UK tax legislation and two of the fundamental freedoms relating to the operation of the European Single Market. It is of course these freedoms (and cases taken to enforce them) that historically have had such an influence on the UK direct tax system. The first decision to be released was Volkerrail Plant Ltd & Ors v HMRC [2020] UKFTT 476 (TC) which considered the...
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Two recent decisions have sought to clarify the extent to which the EU freedom of establishment and of the movement of capital were restricted in light of various UK legislative provisions dealing with cross-border transactions and/or operations, as Dominic Stuttaford and Greg Branagan (Norton Rose Fulbright) explain.
Buried among the flurry of activity leading up to the end of the Brexit transitional period on 31 December 2020 were two judgments by the First-tier Tribunal (FTT) and Upper Tribunal (UT) (respectively) relating to the interrelation between UK tax legislation and two of the fundamental freedoms relating to the operation of the European Single Market. It is of course these freedoms (and cases taken to enforce them) that historically have had such an influence on the UK direct tax system. The first decision to be released was Volkerrail Plant Ltd & Ors v HMRC [2020] UKFTT 476 (TC) which considered the...
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