Legal expenses - whether or not incurred wholly and exclusively for the purposes of the trade
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Whether expense not wholly and exclusively for purposes of trade and disallowed by s54 Corporation Tax Act 2009 - yes –– whether s1290 Corporation Tax Act 2009 excluding deductions for expenses in respect of employee benefit contributions applicable - no - appeal dismissed
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Consideration of whether the Appellant is not entitled to “enhanced research and development allowances” under Chapter 2 of Part 12 of the Corporation Tax Act 2009 because the relevant expenditure for which this relief is claimed is “otherwise met directly or indirectly by a person other than the company” under s 1138(1)(c) of that Act - appeal allowed in principle
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Duty of care and introduction to tax-planning schemes.The High Court rejected a damages claim lodged by clients of an accountancy firm that had introduced them to promoters of a tax scheme that had ultimately failed
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The Court of Appeal delivered its judgment in a case concerning the employment status of professional football referees
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CORPORATION TAX – capital gain realised on sale of property – whether payment to director/former shareholder who was controlling party was deductible – jurisdiction in circumstances where no claim made to use loan relationship deficit before issue of closure notice or expiry of two year time limit - whether payment was a distribution – whether amount deductible as expense or loss from non-trading loan relationship – appeal dismissed
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CORPORATION TAX – s1219 Corporation Tax Act 2009 – company with investment business – expenditure in connection with disposal of assets – whether expenses of management of the company’s investment business – whether expenditure was capital in nature
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The Court of Appeal reversed the decision of the Upper Tribunal (UT) in relation to the question of whether a UK LLP was trading, and if so, whether that trade was being carried on with a view to a profit
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INCOME TAX AND CAPITAL GAINS TAX – sale of serviced building plots in grounds of Grade I listed building – sale proceeds used for restoration of listed building – whether trading or capital gain – appropriation of land from capital to trading stock − principal private residence – extent of permitted area of garden and grounds – whether land “denatured” by construction works – whether “conservation deficit” is deductible expense – whether trust impressed on sale proceeds – imputed market-value on non-arm’s length disposal – s5 ITTOIA – ss 17, 161 and 222 TCGA
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Impact of standstill provision for third country dividends – claim for damages where double taxation relief arises but cannot be used in full because of other reliefs
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