In HMRC v Coal Staff Superannuation Scheme Trustees Ltd (27 April 2022) [2022] UKSC 10 the Supreme Court unanimously allowed HMRC's appeal finding that the UK's (pre 2014) rules for taxing 'manufactured overseas dividends' (income payable by the borrower to a lender in a stock lending arrangement involving non-UK shares) did not contravene the EU principle of free movement of capital. Even if it had contravened this principle the remedy sought by the taxpayer was disproportionate when compared with the breach. Read the decision.
In W Paul v HMRC (25 April 2022) [2022] UKUT 116 (TCC) the UT decided that: (i) a party (whether the appellant or the respondent) requires the UT's permission to argue a point that has not already been argued by that party before the FTT; and (ii) in this case the UT refused permission to HMRC to...
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In HMRC v Coal Staff Superannuation Scheme Trustees Ltd (27 April 2022) [2022] UKSC 10 the Supreme Court unanimously allowed HMRC's appeal finding that the UK's (pre 2014) rules for taxing 'manufactured overseas dividends' (income payable by the borrower to a lender in a stock lending arrangement involving non-UK shares) did not contravene the EU principle of free movement of capital. Even if it had contravened this principle the remedy sought by the taxpayer was disproportionate when compared with the breach. Read the decision.
In W Paul v HMRC (25 April 2022) [2022] UKUT 116 (TCC) the UT decided that: (i) a party (whether the appellant or the respondent) requires the UT's permission to argue a point that has not already been argued by that party before the FTT; and (ii) in this case the UT refused permission to HMRC to...
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