Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing...more
Welcome to March’s edition of our UK Tax Round Up. This month has seen a number of interesting cases covering a range of issues, from the deductibility of costs against employment income to the place of effective management...more
4/10/2024
/ Acquisitions ,
Asset Management ,
Corporate Governance ,
HMRC ,
Income Taxes ,
Investment Management ,
Legislative Agendas ,
Mergers ,
Private Equity ,
Private Equity Funds ,
Shareholders ,
Taxation ,
UK
Settlement payment subject to tax as employment income -
In Mathur v HMRC, the Upper Tribunal (UT) has upheld the FTT’s decision that a £6 million settlement payment to a former employee following an employment tribunal...more
3/11/2024
/ Capital Contributions ,
EU ,
HMRC ,
Income Taxes ,
Interest Rates ,
Investigations ,
Jurisdiction ,
Price Manipulation ,
Professional Regulators ,
Settlement ,
Termination ,
UK
As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more
Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more
Welcome to July’s edition of our UK Tax Round Up. This month has seen a number of interesting tribunal decisions, including the denial of double tax relief and of employee expense deductions and the taxation on loans to a...more
Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more
3/29/2023
/ Beneficial Owner ,
Capital Gains ,
Corporate Taxes ,
Double Taxation ,
HMRC ,
Income Taxes ,
Interest Rates ,
OECD ,
Offshore Funds ,
Private Funds ,
Securities ,
Tax Relief ,
Taxation ,
Value-Added Tax (VAT)
Welcome to February’s edition of our UK Tax Round Up. The month has seen interesting cases on the “entitlement” to income and the single and multiple supply tests for VAT as well as announcement of the publication date for...more
Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more
12/6/2022
/ Appeals ,
Bank Taxes ,
Capital Gains ,
Diverted Profits Tax ,
Dividends ,
HMRC ,
Income Taxes ,
Inheritance Tax ,
OECD ,
Transfer Taxes ,
UK
Welcome to the October edition of the UK Tax Round Up. October has been an extraordinary month in the UK, with political turbulence triggering reversals of many of the tax policies announced by the government at the end of...more
11/1/2022
/ Double Taxation ,
EU ,
European Court of Justice (ECJ) ,
HMRC ,
Income Taxes ,
Interest Rate Adjustments ,
Reversal ,
Tax Liability ,
Tax Policy ,
UK ,
Value-Added Tax (VAT)
Welcome to September’s edition of the UK Tax Round Up. In addition to the headline-grabbing 2022 Growth Plan announced by the UK Chancellor, there have been a number of interesting cases this month including the First-tier...more
9/30/2022
/ Advocate General ,
Business Taxes ,
Debtors ,
Dispute Resolution ,
Double Taxation ,
Enforcement ,
EU ,
European Court of Justice (ECJ) ,
Fair Market Value ,
HMRC ,
Income Taxes ,
Indemnity ,
Purchase Agreement ,
Shareholders ,
Tax Loopholes ,
UK
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
Welcome to July’s edition of the UK Tax Round Up. This month has seen an interesting decision of the First-tier Tribunal on the salaried member rules as they apply to asset manager LLPs, a surprising decision on the terms...more
The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset...more
Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more
6/8/2022
/ Advocate General ,
Corporate Taxes ,
EU ,
Income Taxes ,
International Tax Issues ,
OECD ,
Remuneration ,
Tax Code ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Reform ,
Transfer of Assets ,
UK ,
Value-Added Tax (VAT)
Welcome to the March edition of the Proskauer UK Tax Round Up. In his Spring Statement, the Chancellor focused on measures to alleviate the increasing cost of living and to boost investment in the economy but there were no...more
Welcome to February’s edition of our UK Tax Round Up. This month’s edition includes updated guidance on the VAT treatment of contractual termination payments, updated HMRC guidance on the assessment of “substantial”...more
UK Case Law Developments -
Contributions to remuneration trust scheme not tax deductible -
In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more
2/10/2022
/ Business Losses ,
EU ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Tax Code ,
Tax Court ,
Tax Deductions ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more
12/3/2021
/ Corporate Taxes ,
HMRC ,
Holding Companies ,
Income Taxes ,
International Tax Issues ,
IR35 ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
UK ,
Withholding Tax
In Fashion on the Block Limited v HMRC, the First-tier Tribunal (FTT) has allowed the taxpayer’s appeal against HMRC’s decision not to allow the taxpayer company to issue seed enterprise investment scheme (SEIS) certificates...more
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
Spring Budget and Tax Day -
After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more
UK Case Law Developments -
EIS relief not available for shares carrying preferential rights -
The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more
3/10/2021
/ Corporate Taxes ,
EU ,
European Commission ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
OECD ,
Private Equity ,
Tax Avoidance ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
Extension of support for retail, leisure and hospitality businesses -
Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
2/8/2021
/ Anti-Avoidance ,
Capital Gains ,
Capital Gains Tax ,
Coronavirus/COVID-19 ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Job Retention Schemes ,
Partnerships ,
Tax Avoidance ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)