In B Khan v HMRC [2021] EWCA Civ 624 (30 April 2021) the Court of Appeal dismissed the taxpayer’s appeal and held that the UT’s decision was correct. The taxpayer had received a distribution consisting of the proceeds of a share buyback and was subject to income tax on that amount even though it was part of a larger transaction and the money just flowed through him. The UT did not err when it rejected the taxpayer’s argument that the facts should be recharacterised as a composite transaction (on a Ramsay analysis). We’ll review this case in further detail shortly.
Penalty for careless inaccuracy in SDLT return and 15% rate of SDLT
In MAS Fabrics Hong Kong Ltd v HMRC (TC06641) (30 April 2021) the FTT upheld the penalty. The taxpayer had been careless as it was not sufficient for the...
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In B Khan v HMRC [2021] EWCA Civ 624 (30 April 2021) the Court of Appeal dismissed the taxpayer’s appeal and held that the UT’s decision was correct. The taxpayer had received a distribution consisting of the proceeds of a share buyback and was subject to income tax on that amount even though it was part of a larger transaction and the money just flowed through him. The UT did not err when it rejected the taxpayer’s argument that the facts should be recharacterised as a composite transaction (on a Ramsay analysis). We’ll review this case in further detail shortly.
Penalty for careless inaccuracy in SDLT return and 15% rate of SDLT
In MAS Fabrics Hong Kong Ltd v HMRC (TC06641) (30 April 2021) the FTT upheld the penalty. The taxpayer had been careless as it was not sufficient for the...
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:
