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Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the Canada-UK double tax treaty to the taxation of oil related payments and the application of the statutory residence test and what constitutes “exception circumstances, and updates from HMRC on the latest guidance on the “capital contribution” test in the salaried members rules and taxpayer return information provision related to carried interest.
on February 2025
Welcome to the January 2025 edition of our UK Tax Round Up. This month has seen a very interesting decision of the Court of Appeal on the significant influence test in the salaried member rules and decisions on the tax deductibility of redress payments made instead of penalty payments and the tax treatment of image right payments in the context of IR35.
on January 2025
Welcome to the December 2024 edition of our UK Tax Round Up. This month has seen interesting decisions on the basis for rescission of an arrangement with adverse tax consequences, the treatment of a loan from an EBT, the tax status of a payment relating to resignation as a director and the meaning of interest in the context of a redress payment.
on December 2024
on December 19, 2024
Welcome to the November 2024 edition of our UK Tax Round Up. This month has seen publication of the Finance Bill 2024-25 and interesting cases on the loan relationship unallowable purpose test and the extent that tax applies to employment settlement payments. In addition, HM Treasury is asking for responses to its proposed changes to the carried interest tax rules, which will take effect from 6 April 2026.
on November 2024
Welcome to September's edition of the UK Tax Round Up. This month has seen decisions on UK tax residence, VAT group eligibility and the Supreme Court’s ruling in the long running case involving the employment status of football match officials.
on September 2024
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.
on July 2024
on July 10, 2024
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.
on June 2024
on June 4, 2024
