In this month’s briefing, Mark Middleditch (Allen & Overy) provides a round-up of recent tax developments affecting the City, including: the decisions in Sir Fraser Morrison (contingent CGT liability for shareholder-director) and Project Blue (SDLT anti-avoidance); new tax relief for corporate rescues; and the Office of Tax Simplification’s report on partnership taxation.
More than 100 UK film scheme investors that have been issued with accelerated payment notices (APNs) demanding payment of disputed tax upfront will be able to challenge the policy in the courts.
Stay of proceedings pending decision by the CJEU
Late filing penalty and special circumstances
Confiscation orders and tax
Damages on an undertaking given by HMRC
Geoff Lloyd and Paul Dennis (EY) examine how ADR is working for large businesses
The Indian government will not be appealing the Bombay High Court’s decision in Vodafone lndia Services Pvt. Ltd AY 2009-10 (WP No.871120).
Winding up and the jurisdictions of the Companies court and the FTT
Human Rights Act challenge