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HMRC v Perenco UK Ltd [2023] UKUT 169

Tax Cases and Appeals Crown Copyright
2023-07-19
The Upper Tribunal upheld the decision of the First-tier Tribunal’s decision to allow expenditure claims made by Perenco in respect of the costs of replacing a cooling plant at a gas processing terminal
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HMRC v J Conran; JC Vision Ltd v HMRC [2023] UKUT 166

Tax Cases and Appeals Crown Copyright
2023-07-12
The Upper Tribunal overturned the a decision of the First-tier Tax Tribunal’s decision in relation to whether a payment for the transfer of a licence constituted a distribution
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Strachan v HMRC [2023] UKFTT 617

Tax Cases and Appeals
2023-07-23
The First-tier Tribunal determined that while although the taxpayer had failed to acquire a domicile of choice in Massachusetts having considered all relevant factors into consideration, HMRC had not met the burden of proving that the loss of tax was brought about by carelessness
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GE Financial Investments v HMRC [2023] UKUT 146

Tax Cases and Appeals Crown Copyright
2023-06-29
The Upper Tribunal reversed the decision of the First-tier Tribunal that a UK-resident company was not also US resident for the purposes of the UK–US double taxation treaty
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Hargreaves Property Holdings Ltd v HMRC [2023] UKUT 120

Tax Cases and Appeals Crown Copyright
2023-05-23
The Upper Tribunal dismissed the taxpayer’s appeal against the determination of the First-tier Tribunal’s determination that UK income tax should have been deducted from interest payments on debt financing provided to the group
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Shinelock Ltd v HMRC [2023] UKUT 107

Tax Cases and Appeals Crown Copyright
2023-05-15
Chargeable gain on disposal of property – whether payment made by disposing company to controlling party was a deductible loan relationship debit – whether such payment was a distribution – whether FTT decided issues on basis of arguments which had not been pleaded – raising “new” issues in an FTT hearing – appeal dismissed
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Coller v Revenue and Customs [2023] UKFTT 212 (TC)

Tax Cases and Appeals Crown Copyright
2023-03-28
Income Tax - was the appellant domiciled in England in the tax years ended 5 April 2013 - 5 April 2016 - consideration of domicile of choice of the appellant’s father and mother - Father came to England in 1938 from Austria - had he acquired a domicile of choice in England by the relevant date? - Yes - Mother arrived in England in 1954 from Ireland –had she acquired an English domicile of choice by the relevant date? - yes - appellant born and brought up in England - did he have an English domicile at the relevant date? - yes - appeal dismissed
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N Henderson v HMRC [2023] UKFTT 281

Tax Cases and Appeals Crown Copyright
2023-03-08
Income Tax - returns from share transactions – whether trading activity – no – whether carried on commercially – no – appeal dismissed
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