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Group relief
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Group relief
GROUP-RELIEF
Lloyds Asset Leasing Ltd v HMRC
FTT denies cross-border group relief claim on main purpose grounds.
Tax grouping (part 1): group relief and tax groupings
Maddy Potthast
Gavin Little
In the first in a series of articles on corporate tax issues, Gavin Little and
Maddy Potthast (Interpath) focus on the conditions for corporation tax loss
relief via group relief.
The Tower One St George Wharf Ltd v HMRC
UT denies SDLT group relief because of tax avoidance main purpose.
Share deals: when is the optimum time to sell?
Laura Frenck
Lorna McCaa
Tax implications for sellers will often influence the optimum time to sell a company. Lorna McCaa and Laura Frenck (Dentons) address the main tax implications for UK corporate sellers and the related timing considerations.
Mainly ignored? The main purpose test for SDLT group relief
Helen Coward
Helen Coward (Charles Russell Speechlys) examines the decision in
The Tower One St George Wharf Ltd
concerning the SDLT group relief
anti-avoidance rule.
VolkerRail: applying retained EU case law in pre-Brexit years
Richard Doran
Davinder Sahota
A decision of the Upper Tribunal illustrates the difficulties of applying CJEU case law for disputes over pre-Brexit breaches of EU law, write Richard Doran and Davinder Sahota (EY).
Back to basics: SDLT and partnerships
Anisha Polson
Paul Beausang
Paul Beausang and Anisha Polson (Eversheds Sutherland) provide a
refresher guide to what must be among the most complex of all the SDLT
rules.
EU freedoms in cross-border transactions
Dominic Stuttaford
Greg Branagan
Two recent decisions have sought to clarify the extent to which the EU freedom of establishment and of the movement of capital were restricted in light of various UK legislative provisions dealing with cross-border transactions and/or operations, as Dominic Stuttaford and Greg Branagan (Norton Rose Fulbright) explain.
The new market value rule: swan-song for ‘swamping’
Bridget English
Richard Sultman
Bridget English and Richard Sultman (Cleary Gottlieb Steen & Hamilton)
discuss the proposed extension of the stamp duty/SDRT market value rule.
The draft Finance Bill 2017 rules on CT losses
Ben Jones
Dean Andrews
From 1 April 2017, there will be a substantial change to how corporation tax losses can be carried forward. Ben Jones and Dean Andrews (Eversheds Sutherland) examine the detail.
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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
Tax Journal authors for March
HMRC closing in on tax avoidance (again)
Finance Act 2025 enacted
MPs press ahead with NICs increases
ATED chargeable amounts increased
CASES
Read all
HMRC v Innovative Bites Ltd and another
PD & MJ Ltd v HMRC
LR R&D LLP v HMRC
Other cases that caught our eye: 28 March 2025
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
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
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
Concerns remain over Making Tax Digital
HMRC closing in on tax avoidance (again)
V Louwman v HMRC
B Lynch v HMRC