Welcome to the December 2024 edition of our UK Tax Round Up. This month has seen interesting decisions on the basis for rescission of an arrangement with adverse tax consequences, the treatment of a loan from an EBT, the tax...more
1/3/2025
/ Beneficiaries ,
Compensation ,
HMRC ,
Income Taxes ,
Inheritance Tax ,
Liability ,
National Insurance Contributions ,
Settlement Agreements ,
Tax Avoidance ,
Tax Exemptions ,
Tax Revenues ,
Trusts ,
UK ,
Withholding Tax
Welcome to the September edition of the UK Tax Round Up. This month has seen interesting decisions on the salaried members rules, the scope of arrangements for the CGT rollover main tax avoidance purpose test and the...more
10/12/2023
/ Compensation ,
Film Industry ,
GAAP ,
HMRC ,
Investment ,
Private Limited Companies ,
Subsidies ,
Tax Avoidance ,
Tax Deductions ,
Tax Exemptions ,
Tax Planning ,
UK
Welcome to August’s edition of our UK Tax Round Up. This month has seen two interesting decisions from the Upper Tribunal, the first on the loan relationship unallowable purpose test and the second on the meaning of...more
Welcome to the August edition of the UK Tax Round Up. August turned out to be not such a quiet month on the UK tax front. We have seen several important and technical case law decisions, some of which we discuss below, and...more
UK Case Law Developments -
Taxpayer treated as receiving distribution in tax avoidance case -
We reported on First-tier Tribunal’s (FTT’s) decision in Dunsby v Revenue & Customs in our June 2020 UK Tax Round Up. By way...more
1/5/2022
/ Distribution Rules ,
Dividend-Equivalent Transactions ,
International Tax Issues ,
Legal Costs ,
Proposed Regulation ,
Regulatory Agenda ,
Share Class Structures ,
Stock Options ,
Tax Avoidance ,
Tax Code ,
Tax Court ,
Tax Liability ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
In Haworth v HMRC the Supreme Court (SC) upheld the Court of Appeal’s (CA’s) decision to quash a follower notice (FN) and accelerated payment notice (APN) issued to the taxpayer, Mr Haworth. An FN can be issued by HMRC where...more
8/2/2021
/ Accelerated Payments ,
Bonuses ,
Charitable Trusts ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
NICS ,
OECD ,
Preferred Shares ,
Proposed Legislation ,
Regulatory Agenda ,
Remuneration ,
Tax Avoidance ,
Tax Reform ,
UK ,
Valuation ,
Value-Added Tax (VAT)
UK Case Law Developments -
Income tax consequences of pension-related payments in E.ON v HMRC -
E.ON v HMRC concerned a large UK power and gas supplier, which paid certain lump sum payments, called “facilitation...more
7/6/2021
/ Corporate Taxes ,
Double Taxation ,
Employee Benefits ,
HMRC ,
Income Taxes ,
International Tax Issues ,
OECD ,
Pension Schemes ,
Pensions ,
Tax Avoidance ,
UK
Following the UK general election on 8 June 2017, at which Theresa May’s Conservative party won the largest number of seats but lost its overall majority, the Queen’s Speech setting out the now minority Conservative...more