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VolkerRail Plant Ltd & Ors v HMRC [2023] EWCA Civ. 210

Tax Cases and Appeals Crown Copyright
2023-03-01
The case concerned a UK-resident company whose ultimate parent was located in the Netherlands. Losses were incurred by a UK permanent establishment (PE) of a company resident in the Netherlands. The UK-resident company attempted to claim those losses through consortium and group relief
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2 Green Smile Ltd v HMRC [2023] UKFTT 15

Tax Cases and Appeals Crown Copyright
2022-12-20
Transfer of the business and goodwill of a dental practice from a partnership to a connected company – date of transfer – appellants say 1 December 2014 – HMRC say 23 October 2015 and amend partnership return to assess the partners for income between those dates and issue closure notices to the company denying amortisation of goodwill – oral agreement to transfer ineffective by virtue of The Law of Property (Miscellaneous Provisions) Act 1989 – grandfathering provision? - cannot apply – de facto transfer?
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Urenco Chemplants and another v HMRC [2022] EWCA Civ. 1587

Tax Cases and Appeals Crown Copyright
2022-12-01
This case concerns the availability of capital allowances for expenditure on the construction of a specialised facility for the treatment and management of highly toxic and radioactive waste in the civil nuclear industry, by a process known as “deconversion”
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Centrica Overseas Holdings Limited v HMRC [2022] EWCA Civ. 1520

Tax Cases and Appeals Crown Copyright
2022-11-18
Reversing the decision of the Upper Tribunal which originally determined that advisor fees incurred by an intermediate UK holding company (COHL) in the Centrica Plc group were deductible expenses of management under UK equivalent of section 83 TCA 1997
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Mrs A v HMRC [2022] UKFTT 421

Tax Cases and Appeals Crown Copyright
2022-11-14
s225 ITEPA 2003 - whether payment for a restrictive undertaking in connection with the individual’s current, future or past employment - yes - section 401 ITEPA 2003 - whether payment to appellant by employer under settlement agreement indirectly in consequence of, or otherwise in connection with, the termination of employment - yes - appeal dismissed
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Gould v HMRC [2022] UKFTT 431

Tax Cases and Appeals Crown Copyright
2022-11-01
Interim dividend – payment to shareholders on different dates - whether later dividend due and payable when first dividend paid – no
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Aozora GMAC Investment Ltd v HMRC [2022] UKUT 258 (Aozora GMAC Investment Ltd v HMRC [2022] UKUT 258 )

Tax Cases and Appeals Crown Copyright
2022-09-23
The Upper Tribunal dismissed HMRC's appeal, upholding the First-tier Tribunal judgment that relevant UK legislation at the time did not deny unilateral relief by way of credit for US withholding tax on interest, notwithstanding the fact that the taxpayer was not entitled to relief under the UK/US double tax treaty as a result of the limitation on benefits provision
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Burlington Loan Management v HMRC [2022] UKFTT 290

Tax Cases and Appeals Crown Copyright
2022-08-22
Appeal by the Appellant, an Irish resident company, against a refusal by the Respondents to repay to the Appellant income tax withheld at source in respect of interest paid on a debt owed by a UK resident company – refusal based on the Respondents’ view that Article 12(1) of the double tax treaty between the UK and the Republic of Ireland (the “Treaty”) did not apply to the interest as a result of Article 12(5) of the Treaty, which precluded the article from applying where one of the persons concerned with the assignment had a main purpose of taking advantage of the article by means of the assignment – held that Article 12(5) of the Treaty did not apply to the Appellant in respect of the interest because no person who was concerned with the assignment of the debt had obtaining the benefit of Article 12(1) of the Treaty by means of the assignment as one of its main purposes
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HMRC v Keith Murphy [2022] EWCA Civ 1112

Tax Cases and Appeals Crown Copyright
2022-08-04
The Court of Appeal held that a success fee and indemnity premium paid under an employment related settlement was taxable as employment income
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