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HMRC v Euromoney Institutional Investor plc [2022] UKUT 205

Tax Cases and Appeals Crown Copyright
2022-07-29
Corporation Tax – S137 of Taxation of Chargeable Gains Act 1992 - whether exchange of shares part of a scheme or arrangements of which the main purpose, or one of the main purposes, is avoidance of liability to corporation tax – appeal dismissed
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Inmarsat Global Ltd v HMRC [2022] EWCA Civ. 1076

Tax Cases and Appeals Crown Copyright
2022-07-28
What is at issue in these proceedings is whether the appellant, Inmarsat Global Ltd is entitled to capital allowances on costs incurred by the International Maritime Satellite Organisation to whose trade Inmarsat has succeeded, on the launch of certain satellites. The case raises questions as to the interpretation and application of s61(4) and 78 of the Capital Allowances Act 1990 and how those provisions interact
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Foundation Partners v HMRC [2022] UKUT 167

Tax Cases and Appeals Crown Copyright
2022-07-27
The Upper Tribunal rejected the general partnership's appeal against the finding that its activities carried out in 2008-09 did not constitute a trade
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Slade v HMRC [2022] UKFTT 227

Tax Cases and Appeals Crown Copyright
2022-07-26
CGT – section 38 TCGA 1992 – deductible expenditure – expenditure not wholly and exclusively incurred in preserving or defending title to the asset – appeal dismissed
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HMRC v BlackRock Holdco 5 LLC [2022] UKUT 199

Tax Cases and Appeals Crown Copyright
2022-07-19
Case in relation to the deductibility of interest payable on $4 billion worth of loan notes. The loan notes were part of intra-group financing for a third-party corporate acquisitio
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S Kavanagh v HMRC [2022] UKFTT 173

Tax Cases and Appeals Crown Copyright
2022-05-31
Capital Gains Tax – entrepreneurs’ relief – Taxation of Chargeable Gains Act 1992, sections 169I and 169S – whether or not the appellant held at least 5% of the ordinary share capital of the company and at least 5% of the voting rights by virtue of that holding – no - whether or not shares were held on trust for the appellant – no – appeal dismissed
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Ignatius Tedesco v HMRC [2022] TC8498

Tax Cases and Appeals Crown Copyright
2022-05-27
Capital Gains Tax – calculation of gain upon disposal of shares in company – costs of disposal – Section 38(1)(b) TCGA 1992 – Appellant repaid company debt prior to share sale – whether this constitutes expenditure on the shares that is reflected in their state or nature at disposal – Aberdeen Construction and Blackwell applied – held “no” – appeal dismissed
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