News & Analysis as of September 22, 2024

Tax Tribunal

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Brakes Applied to a Speedy Reorganisation

Cadwalader, Wickersham & Taft LLP on 1/27/2023

The Upper tax tribunal (“Upper Tribunal”) has confirmed the decision of the First-tier tax tribunal (“FTT”), delivered in 2021, in the case of Kwik-Fit Group Limited and others v HMRC. This decision of the Upper Tribunal...more

Court of Appeal decides that Jersey companies were UK tax resident

Proskauer - Tax Talks on 12/28/2020

In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the...more

Advisers’ fees non-deductible where management decisions made by parent company

Proskauer - Tax Talks on 6/1/2020

The UK’s First-tier tax tribunal (FTT) has just released an interesting decision considering whether or not expenses incurred by a parent company on advisers’ fees that related to a proposed disposal by a group subsidiary and...more

UK Tax Round Up - September 2018

Proskauer Rose LLP on 10/8/2018

UK Case Law Developments - Entrepreneurs' relief – voting rights not imputed for equitable reasons - In George v HMRC, the First Tier Tribunal (FTT) decided that they could not apply the equitable principle that...more

UK Tax Round Up - January 2018

Proskauer Rose LLP on 1/29/2018

The impact of discounts on consideration for VAT purposes (Finanzamt Bingen-Alzey v Boehringer Ingelheim Pharma GmbH & Co. KG) - The ECJ has confirmed that consideration for VAT purposes should be reduced by any discount...more

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