Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Limits of the distinct and separate enterprise fiction
Attribution of profits to a permanent establishment (PE) of a non-resident company is not straightforward and partnerships can also raise complex issues. Put these two topics together and you get a 38-page decision of the First-tier Tribunal (FTT) in Bloomberg Inc & BLP Acquisition Holdings LLC v HMRC [2018] UKFTT 205 (TC). The appellants are US resident companies each liable to UK corporation tax through having a PE in the UK. They are liable to tax on the profits attributable to their respective PEs. In the corporation tax returns for the PEs the appellants made elections under FA 2002 Sch 29 (rewritten to CTA 2009 Part 8) for intangible fixed assets (IFAs).
The IFAs were in a Delaware limited partnership ...
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Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Limits of the distinct and separate enterprise fiction
Attribution of profits to a permanent establishment (PE) of a non-resident company is not straightforward and partnerships can also raise complex issues. Put these two topics together and you get a 38-page decision of the First-tier Tribunal (FTT) in Bloomberg Inc & BLP Acquisition Holdings LLC v HMRC [2018] UKFTT 205 (TC). The appellants are US resident companies each liable to UK corporation tax through having a PE in the UK. They are liable to tax on the profits attributable to their respective PEs. In the corporation tax returns for the PEs the appellants made elections under FA 2002 Sch 29 (rewritten to CTA 2009 Part 8) for intangible fixed assets (IFAs).
The IFAs were in a Delaware limited partnership ...
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:
