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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
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Newsletter
Welcome to August’s edition of our UK Tax Round Up. This month has seen two interesting decisions from the Upper Tribunal, the first on the loan relationship unallowable purpose test and the second on the meaning of “exceptional circumstances” for the statutory residence test.
August 2023
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Newsletter
Welcome to July’s edition of our UK Tax Round Up. This month has seen a number of interesting tribunal decisions, including the denial of double tax relief and of employee expense deductions and the taxation on loans to a company director, as well as the publication of draft legislation for the Finance Bill 2024 and the ratification by Luxembourg of the new UK-Luxembourg double tax treaty.
July 2023
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Newsletter
Welcome to June’s edition of our UK Tax Round Up. Several interesting cases have been reported this month, including a range of issues relevant to UK withholding tax on interest being considered in Hargreaves. HMRC has also launched two noteworthy consultations, one on the UK’s permanent establishment and transfer pricing rules and another looking at SAYE and SIP share schemes.
June 2023
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Newsletter
Welcome to May’s edition of our UK Tax Round. This month has been relatively quiet but there were a couple of cases that affect transactions that we see in practice, including an interesting update on what could constitute a results dependent distribution payment for a UK company.
May 2023
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Newsletter
Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting cases highlighting the need to taxpayers and HMRC alike to apply a realistic approach to the facts in assessing the tax consequences of uncommon arrangements and also saw HMRC publish its proposals for modernising elements of the tax system as its Tax administration and maintenance publications, including a consultation on stamp taxes on shares.
April 2023
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Newsletter
Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group members and the application of the miscellaneous income tax provision to a reallocation of funds from an LLP to its members.
March 2023
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Newsletter
Welcome to February’s edition of our UK Tax Round Up. The month has seen interesting cases on the “entitlement” to income and the single and multiple supply tests for VAT as well as announcement of the publication date for the next Finance Bill and HMRC guidance on the imminent changes to the CSOP regime.
February 2023
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Newsletter
Welcome to the January edition of the UK Tax Round Up. This month has been reasonably quiet, with another IR35 case decision and a decision on the recovery of input VAT incurred on a corporate fundraising and acquisition transaction among other developments.
January 2023