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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 …
Supreme Court provides guidance on Follower Notices
In R (on the application of Haworth) v HMRC [2021] UKSC 25, the Supreme Court has upheld the Court of Appeal's decision quashing a follower notice issued …
What is "reasonable detail" when notifying a tax claim under an SPA?
In Dodika Limited (and others) v United Luck Group Holdings Limited [2021] EWCA Civ 638, the Court of Appeal held that the Defendant had complied with …
HMRC's ability to argue fraudulent misrep hindered
In IGE USA Investments Limited v HMRC [2021] EWCA Civ 534, the Court of Appeal overturned part of an interlocutory decision of the High Court dealing …
Notification of Uncertain Tax Treatment - our response to the Consultation
In March 2020 Her Majesty’s Revenue and Customs (“HMRC”) released a consultation document (the "ConDoc") regarding a new proposal to bring forward …
Mutual mistake and rectification: lessons to be learned from MV Promotions v TMG
A number of important points emerge from the recent decision in MV Promotions Limited and Micheal Vaughan v Telegraph Media Group Limited and HMRC [2020] …
Relief for management expenses: Centrica v HMRC examined
The Centrica decision is about whether certain expenses incurred by the taxpayer in making a corporate disposal were deductible as "expenses of …
Tax Treaty Interpretation: The Limits of Fiction
In Fowler v HMRC [2020] UKSC 22, the Supreme Court determined that a statutory fiction created by a deeming provision of UK tax law did not …
Court of Appeal considers corporation tax deductibility of ‘derecognised’ derivative contracts
In The Union Castle Mail Steamship Company Ltd v HMRC & Ors [2020] EWCA Civ 547, the Court of Appeal considered whether corporation tax …
Government announces review of implementation of IR35 private sector reforms
The government announced on 7 January 2020 that it is launching a review of the implementation of the changes to off-payroll working rules (commonly …
Post-Brexit Customs Regime
With a Brexit deal still out of reach, the UK government has introduced the Taxation (Cross-border Trade) Act 2018 setting out the customs regime for …
Supreme Court denies compound interest in taxpayer's claim against HMRC
In Littlewoods Ltd and others v HMRC [2017] UKSC 17, the Supreme Court delivered a controversial decision allowing HMRC's appeal, which means that …
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