UK corporate offence of failure to prevent tax evasion
Schemes of arrangement are a vastly flexible mechanism to implement take private transactions and other restructuring in respect of Guernsey companies. Schemes are, in effect, a legally enforceable arrangement or...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
The United Kingdom has long been a target destination for activist investors. It is the venue for nearly half of all of recent activist campaigns in Europe. In previous articles, we have discussed how informed boards should...more
Case Law Developments - Place of supply for VAT purposes - The recent case of American Express Services Europe Limited (AESEL) v HMRC is a useful reminder of the well-established two-stage approach to determining the...more
UK Case Law Developments - Valid notice crucial to tax indemnity claim - The Court of Appeal (CA) decision in Stobart Group Ltd v Stobart and another is a cautionary tale for any purchaser who, following the...more
Development Securities plc and others v HMRC [2019] UKUT 169 (TCC) - The Original Judgment - As we reported in our August 2017 UK Tax Round-Up [https://www.proskauer.com/newsletter/uk-tax-round-up-august-2017], the...more
UK Case Law Developments - Damages on share sales same as on other sales - In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in...more
General UK Tax Developments - CIOT responds to the draft profit fragmentation provisions in the Finance Bill 2019 - The Chartered Institute of Taxation (CIOT) has published its response to the profit fragmentation...more
General UK Tax Developments - Enterprise management incentive (EMI) options State Aid approval - We referred in the April UK Tax Round Up to the expiry of the EU's State Aid approval for EMI options. Fortunately, this...more