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IPT
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Settlements
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Settlements
SETTLEMENTS
ScottishPower and the limits of von Glehn
Rupert Shiers
Suzanne Hill
Rupert Shiers and Suzanne Hill (Hogan Lovells) examine a recent ruling on whether a corporation tax deduction is allowable for significant expenditure in settling a regulatory investigation.
L v HMRC
FTT holds discrimination settlement payment not taxable.
Clipperton revisited: open questions
Oliver Marre
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and
its implications going forward.
School fee planning: back in the Spotlight
Gordon W Buist
Gordon W Buist (EQ Accountants) examines the impact of the settlements legislation on school fee planning arrangements.
Disguised remuneration: the new settlement opportunity
Tom Wallace
Thomas Wallace (WTT Consulting) explains what advisers need to do
to take advantage of the variety of tax treatments that are on offer.
Purpose and logic: Dunsby as a very modern tax case
Oliver Marre
Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005.
Murphy: earnings as profits and settlement payments
Darren Oswick
Matthew Norris
Darren Oswick and Matthew Norris (Simmons & Simmons) review a recent decision which suggests that insufficient attention has been paid to the ‘profit’ element of the earnings definition.
Seven lessons from Clipperton
Oliver Marre
A recent tribunal decision provides lessons on the settlement provisions,
Ramsay
and piercing the corporate veil, writes barrister Oliver Marre
(5 Stone Buildings).
Practical aspects of HMRC’s retrospective change on VAT and contract terminations
Clara Boyd
On 2 September 2020, HMRC published Revenue & Customs Brief 12/2020 setting out a change in the VAT treatment of payments made in respect of contract terminations and contractual disputes. HMRC’s new general rule is that most such payments will be...
Do HMRC’s allegations of fraud against GE signal a new era in tax investigations?
Helen Buchanan
John Tolman
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) examine
what is effectively the pilot episode for an upcoming courtroom drama.
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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
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
Tax Journal authors for March
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
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