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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 …
Showing 6 out of 6 results