Tax UK Notes

Tax: M&A Outlook for 2025

Court of Appeal confirms pre-construction development costs can qualify for capital allowances

Full-time result in employment status dispute

HFFX: Court of Appeal upholds defeat of incentivisation scheme

Territorial limits on VAT grouping (and on HMRC's power of refusal)

Relief for management expenses

Share sale VAT recovery

Hargreaves Property Holdings: withholding on yearly interest

Royal Bank of Canada: A common sense approach to tax treaty interpretation

Introduction In Royal Bank of Canada v HMRC [2023] EWCA Civ 695, the Court of Appeal upheld the taxpayer's appeal in a case relating to the …

Third party access to pleadings in the FTT

In Cider of Sweden Ltd v HMRC (Ernst & Young LLP (Third Party)) [2022] UKFTT 76 (TC), the First-tier Tribunal ("FTT") has issued a significant, but …

High Court finds no duty owed to investors by barrister advising scheme promoter

Judgment was handed down by Zacaroli J today in McClean & Others v Thornhill [2022] EWHC 457 (Ch). The decision will be of interest to …

No input VAT deduction for VAT not in fact charged

In Zipvit Ltd v HMRC (Case C-156/20), the Court of Justice of the European Union ("CJEU") has held that, where a contract for services provides for VAT …