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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 …
HSF Trust Companies Survey - Tax Insights
We asked trust companies questions about the most significant risk and compliance issues they face. The survey mapped which specific tax compliance …
Rapid resolution of domicile disputes: be careful what you wish for
In Henkes v HMRC [2020] UKFTT 7645 (“Henkes”), the First-tier (Tax) Tribunal (“the Tribunal”) held that (a) it could (and would) …
Zipvit: Supreme Court refers questions to Europe
The Supreme Court has made a referral to the Court of Justice of the European Union (the "CJEU") of questions concerning the availability of input VAT …
HMRC guidance on statutory residence test and COVID-19
HMRC has updated its guidance on the Statutory Residence Test (“SRT”) to extend the exceptional circumstances disregard to cover COVID-19. When …
Lloyd-Webber v HMRC: Music to off-plan investors' ears?
In a decision that will be a welcome source of comfort for investors in potentially risky off-plan property developments, the First-tier Tribunal (Tax) …
High Court strikes out claim against banks in their capacity as lenders to investors of a tax deferral scheme
The High Court has struck out claims brought by former investors in the Ingenious Media tax deferral schemes against lending banks who advanced sums to …
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 …
Discovery Assessments after Tooth: it's never too late, it seems
Where a loss of tax has been brought about deliberately by a taxpayer, the time limit for HMRC to raise a discovery assessment is increased from 4 years …
The extra-territorial reach of HMRC's investigatory powers
In R (on the application of Jimenez) v the First-tier Tribunal (Tax Chamber) and HMRC ("Jimenez"),1 the Court of Appeal determined that HMRC had …
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 …
Limitation on who is a "Relevant Data Holder": a snoop too far?
Wilsons Solicitors LLP v HMRC ("the Wilsons case")1 is an interesting decision of the First-tier Tribunal (Tax Chamber) ("FTT"). It arises …
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