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Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises. The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more
A tax on failure - Empty property rates is a tax on failure; the failure of the owner to find either a profitable use for the premises or a tenant to pay a rent. Since March 2020, reliefs have been available to cushion...more
UK investment managers paying fee rebates, loyalty bonuses or similar payments to UK investors and certain non-UK investors in collective investment schemes should note recent case law developments regarding the tax treatment...more
The Upper Tribunal (Tax and Chancery Chamber), the UK’s second level tax appeal court, have just published their judgement in the McQuillan case, which considered whether shares with no right to dividends or any other profits...more