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Income tax
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Income tax
INCOME-TAX
BlueCrest Capital Management LP and others v HMRC
Court of Appeal confirms that treatment of final PIP awards are liable to income tax.
Top ten cases of 2023
Each week,
Tax Journal
reports notable judgments on tax issues that have been handed down by the courts and tribunals. This week, we also look back over 2023 and highlight some cases of interest to a wide range of advisers.
Resetting the clock and the six-year itch: non-domiciliaries resuming UK tax residence
Claire Weeks
Clare Maurice
Claire Weeks and Clare Maurice (Maurice Turnor Gardner) explain why
returning to the UK after a period of non-tax residence is not for the faint
hearted.
Atholl House Productions Ltd v HMRC
Taxpayer wins finely balanced IR35 case remitted from Court of Appeal.
Ask an expert: A case study on de-enveloping
Marc Selby
If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
Transfer pricing and intangibles: are all the issues priced in?
Alex Rigby
James Anderson
James Anderson and Alex Rigby (Skadden) examine HMRC’s package of
proposed transfer pricing reforms, and consider how they might assist with
existing uncertainty and double taxation disputes.
Blurred lines: occupation, profession or vocation?
Liesl Fichardt
Emily Au
Identifying an occupation is a cornerstone of the sale of occupational income rules. As those rules are increasingly invoked by HMRC, Liesl Fichardt and Emily Au (Quinn Emanuel) examine the guiding principles to identify an occupation, profession and vocation, and highlight the areas of obscurity.
How to handle venture capital tax reliefs
Mark Ward
Mark Ward (BDO) explains the qualifying conditions, benefits for investors
and practical points when claiming relief.
Legislation day highlights
Rhiannon Kinghall Were
Rhiannon Kinghall Were (Macfarlanes) examines the draft legislation and
other policy measures published this week.
Five proposed structural changes to the UK tax system
Sarah Gabbai
Sarah Gabbai (McDermott Will & Emery) proposes five reforms that aim to
increase revenues and simplify the UK tax system.
Go to page
of
7
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
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
HMRC increase late-payment interest rates
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
Chancellor hints on digital services tax
Country-by-country reporting goes public