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GE Financial Investments v HMRC
Residence and the UK/USA double tax treaty.
Civic Environmental Systems Ltd v HMRC
Disregarding carry-back loss claim in closure notice appeal.
Other cases that caught our eye: 7 July 2023
HICBC and discovery assessment powers: There is no sign of the flow of high income child benefit charge (HICBC) cases drying up. HMRC presumably hoped that the retrospective legislation to reverse the decision in Wilkes [2020] UKUT 150 (TCC), where...
Royal Bank of Canada v HMRC
Double tax treaty did not confer UK taxing rights to oil royalty payments.
Raystra Healthcare Ltd v HMRC
CJRS denied for employees omitted from RTI return.
Partnership tax disputes: referral to the FTT
David Whiscombe
Can it really be right that the taxability (or not) of a receipt can be determined by the partnership, with the recipient partner having no right to object? David Whiscombe (David Whiscombe LLP) discusses a tribunal decision that considered for the first time the scope of TMA 1970 s 12ABZB.
Is payroll closely connected to welfare work for VAT purposes?
Victor Cramer
Victor Cramer (Stewarts) writes about the potential wider impact of the
Cheshire Centre for Independent Living
decision on payroll services in the care
sector, and questions whether the decision is correct.
Newey redux
Etienne Wong
Barrister Etienne Wong (Old Square Tax Chambers) examines the lengthy litigation that still leaves a number of outstanding questions.
Civil or criminal proceedings for serious fraud?
David Sleight
David Sleight (Kingsley Napley) examines a recent Upper Tribunal decision which is important for both tax and criminal litigators alike.
EU’s financial transaction tax: where are we now?
The wrong track or the wrong tax?
Go to page
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6
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 4 April 2025
Urgent action could be required on non-dom ‘double remittances’
HMRC set out Pillar Two territories
Additional information requirements for creative industry claims updated
Private schools VAT challenge
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
HMRC v Bolt Services UK Ltd
Other cases that caught our eye: 4 April 2025
HMRC v Innovative Bites Ltd and another
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC closing in on tax avoidance (again)
HMRC v Innovative Bites Ltd and another
Excluded property trusts and 6 April 2025
Country-by-country reporting goes public
Chancellor hints on digital services tax