Tax UK Notes

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 …

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 …