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Newsletter
Welcome to June's edition of the UK Tax Round Up. This month features the latest Court of Appeal decision in a trilogy of recent cases regarding the loan relationship “unallowable purpose” test, an Upper Tribunal decision regarding the application of the old “abuse” provision in the Ireland/UK double tax treaty and further development in the line of recent IR35 decisions.
June 2024
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Newsletter
Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing arrangement, whether interest paid on intragroup loans was “yearly” and the recipient was “beneficially entitled” to it and on the approach that should be taken by the courts in constructing the hypothetical contract required to ascertain whether an individual should be treated as a deemed employee under the IR35 rules among other things.
April 2024
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Newsletter
Welcome to May’s edition of the UK Tax Round Up. This month has seen three interesting tribunal decisions on the unallowable purpose test applied to intragroup loan arrangements, the meaning of income tax advantage in the transactions in securities rules and VAT recovery on advisers’ fees in a share sale.
May 2024
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Newsletter
Welcome to July's edition of the UK Tax Round Up. This month features a call for evidence from the government on potential changes to the tax on carried interest and interesting decisions on the application of the carried interest tax regime rules, the non deductibility of costs related to share and business sales, whether a UK company was resident in the US for double tax treaty purposes by reason of domestic US tax rules and a “special capital” scheme on similar terms to the recent BlueCrest case.
July 2024
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Newsletter
Welcome to July’s edition of our UK Tax Round Up. This month has seen more COVID-19 related developments, including confirmation that time spent on furlough will not adversely affect an employee’s eligibility to hold qualifying enterprise management incentive share options. In addition, the Finance Act 2020 was granted Royal Assent on 22 July.
July 2020
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Newsletter
Welcome to May’s edition of our UK Tax Round Up. COVID-19 developments continue to dominate the government’s focus, but in addition there have been some interesting cases reported on and a scathing report from the Economic Affairs Finance Bill Sub-Committee on the off-payroll worker (IR35) regime and the proposed changes to it.
May 2020
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Newsletter
Welcome to March's edition of our UK Tax Round Up. This has been a monumentous month, starting with the Budget on 11 March and then publication of the Finance Bill, the delay to the implementation of the IR35 rules for private sector workers and the various further announcements by the Chancellor aimed at providing assistance to people in the case of the COVID-19 crisis.
March 2020
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Newsletter
Welcome to April’s edition of our UK Tax Round Up. This month has been dominated by the COVID-19 crisis and the UK government’s response to it. However there have also been some interesting judgements in the UK courts relating to VAT and derivative contracts.
April 2020
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Newsletter
Welcome to the February issue of UK Tax Round Up. February has seen some interesting developments in and relating to the imminent IR35 rule changes and the addition of the Cayman Islands to the EU's blacklist of countries deemed to be guilty of non-cooperation in the area of tax.
February 2020
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Newsletter
Key developments in June 2020
June 2020