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Newsletter
Welcome to June's edition of the UK Tax Round Up. This month features the latest Court of Appeal decision in a trilogy of recent cases regarding the loan relationship “unallowable purpose” test, an Upper Tribunal decision regarding the application of the old “abuse” provision in the Ireland/UK double tax treaty and further development in the line of recent IR35 decisions.
June 2024
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Newsletter
Welcome to May’s edition of the UK Tax Round Up. This month has seen three interesting tribunal decisions on the unallowable purpose test applied to intragroup loan arrangements, the meaning of income tax advantage in the transactions in securities rules and VAT recovery on advisers’ fees in a share sale.
May 2024
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Newsletter
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 arrangement, whether interest paid on intragroup loans was “yearly” and the recipient was “beneficially entitled” to it and on the approach that should be taken by the courts in constructing the hypothetical contract required to ascertain whether an individual should be treated as a deemed employee under the IR35 rules among other things.
April 2024
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Newsletter
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 of a Mauritian trust. In addition, the Chancellor announced significant changes to the UK’s so called “non dom” rules in the Spring Budget and the new Finance Bill has been published.
March 2024
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Newsletter
Welcome to February’s edition of our UK Tax Round Up. This month has seen revised HMRC guidance on the capital contribution limb of the salaried member test and an interesting case on the tax basis for an employment termination settlement payment.
February 2024
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Newsletter
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, another IR35 case was reported and a wide range of interesting issues arose in Keighley.
January 2024
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Newsletter
Welcome to December’s edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income, the latest instalment in the BlueCrest partner incentivisation plan case, an attempt to use cases invented by ChatGPT as evidence, publication of the Finance Bill and the revised UK/Luxembourg double tax treaty coming into force.
December 2023
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Newsletter
Welcome to November’s edition of the UK Tax Round Up. This month has seen the Chancellor’s Autumn Statement as well as an interesting confirmation from the Court of Appeal on the scope of “arrangements” for capital gains tax rollover purposes and the Supreme Court’s decision on who is a transferor for the purposes of the transfer of assets abroad rules.
November 2023
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Newsletter
Welcome to the October edition of the UK Tax Round Up. This month has seen the Supreme Court’s judgment on the operation of the employment-related securities deeming provision, the Court of Appeal’s decision on what constitutes receipt of profits in a fiduciary capacity in the latest BlueCrest case, a number of interesting VAT cases and a policy paper and draft legislation confirming how EU law will remain relevant to the UK’s VAT law.
October 2023
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Newsletter
Welcome to the September edition of the UK Tax Round Up. This month has seen interesting decisions on the salaried members rules, the scope of arrangements for the CGT rollover main tax avoidance purpose test and the precedence of the employment-related securities option rules over the tax-exempt termination payment rules. In addition, the Government has confirmed the repeal of the stamp duty and SDRT 1.5% charge on the issue and transfer of UK securities into depositary receipt or clearance service systems for capital raising.
September 2023