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Newsletter
Welcome to October’s edition of our UK Tax Round Up. In the UK, the First-tier Tribunal ruled in Dialog Semiconductor Ltd v HMRC that a $137 million break fee was not a chargeable gain, providing useful guidance on the tax treatment of termination payments. The Upper Tribunal also granted limited permission to appeal in Syngenta Holdings Ltd v HMRC, reopening important questions around the commercial purpose test and apportionment of interest deductions. At the EU level, the Council of the European Union announced its latest revisions to the list of non-cooperative tax jurisdictions, with Vietnam’s removal from Annex II and new commitments made by five jurisdictions to enhance tax transparency.
October 2025
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Newsletter
September 2025
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Newsletter
August 2025
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Newsletter
July 2025
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Newsletter
June 2025
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Newsletter
Welcome to the May edition of our UK Tax Round Up, which discusses two interesting judgments, one on the question of whether a distribution from a Jersey company was of a “capital nature” and the other on whether a loan to a participator in a close company was “released”.
May 2025
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Newsletter
Welcome to April’s edition of our UK Tax Round Up. While this month has been quiet on the case law front, there have been a number of HMRC announcements and updates to prior published guidance along with published responses to consultations covering aspects of the salaried member rules, globally mobile employees, stamp taxes on shares and the permanent establishment, transfer pricing and diverted profits tax rules.
April 2025
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Newsletter
Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the Canada-UK double tax treaty to the taxation of oil related payments and the application of the statutory residence test and what constitutes “exception circumstances, and updates from HMRC on the latest guidance on the “capital contribution” test in the salaried members rules and taxpayer return information provision related to carried interest.
February 2025
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Newsletter
Welcome to the January 2025 edition of our UK Tax Round Up. This month has seen a very interesting decision of the Court of Appeal on the significant influence test in the salaried member rules and decisions on the tax deductibility of redress payments made instead of penalty payments and the tax treatment of image right payments in the context of IR35.
January 2025
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Newsletter
Welcome to the December 2024 edition of our UK Tax Round Up. This month has seen interesting decisions on the basis for rescission of an arrangement with adverse tax consequences, the treatment of a loan from an EBT, the tax status of a payment relating to resignation as a director and the meaning of interest in the context of a redress payment.
December 2024