Asset managers established as LLPs will welcome the Upper Tribunal’s recent decision to uphold the decision of the First Tier Tax Tribunal (“FTT”) on the application of the salaried member rules in Bluecrest...more
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
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
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 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
Prevention is better than cure In today’s tax environment, where disputes with HMRC can be prolonged and the outcome uncertain, taxpayers would be well advised to take all reasonable steps to minimise the risk of a dispute...more
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
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
UK Tax News and Developments - Government White Paper on Customs Bill - On 9 October, the Government published a White Paper setting out its approach to the introduction of a new customs and VAT regime after the UK...more
UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...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
UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more
A recent decision of the Upper Tribunal (Tax and Chancery Chamber) (UT) in Scambler and another v HMRC [2017] UKUT 1 (TCC) considers the question of when it is appropriate to look back to earlier versions of tax legislation...more
Since the financial crisis of 2008 / 2009, swathes of new regulations have been introduced governing various aspects of remuneration in the financial services sector. A key feature of these rules is the compulsory clawback of...more