Andrew Goldstone and Jeffrey Lee (Mishcon de Reya) review recent private client tax developments that matter, including the decisions in McQuillan, X-Wind Power, Mabbutt and Shah.
The Court of Appeal has handed down its judgment in the Prudential case, in what is hoped to be one of the final steps of this long lasting action between taxpayers invested in cross border portfolio holdings and HMRC. Simon Whitehead and Philippe Freund (Joseph Hage Aaronson), who acted for the taxpayers, summarise the outcome of this judgment and explain why it has taken so long.
The changes to the taxation of dividends proposed in the Budget seem to be worthy of rather more attention than they have received, writes Peter Vaines.
Tony Beare (Slaughter and May) examines the recent eagerly anticipated First-tier Tribunal decision of Next Brand Ltd v HMRC on dividend boosters.
Jeanette Zaman and Emma Game (Slaughter and May) consider whether the conditions for demergers to qualify as exempt distributions are in need of an overhaul
Chris Morgan reviews recent developments in the international arena, including Italy’s ‘Google tax’, the Swiss government’s report on ‘corporate tax reform III’ and Austria’s group tax proposals
Chris Morgan reviews recent developments, including the recent CFC and dividend group litigation (Prudential Assurance Company Ltd), the AG’s opinion in Felixstowe and Emerging Market Series, and updates to tax rules in Brazil, Ireland and Norway.
Michael Anderson and Samantha Wilson examine the recent High Court ruling on Prudential, the test case in the CFC and dividend GLO.
Philip Fisher warns of potential challenges from HMRC to long accepted tax planning techniques involving dividends, following the decision by PA Holdings to withdraw its appeal to the Court of Appeal judgment.