Treaty interpretation - the First-tier Tribunal (FTT) held that a UK-resident company was not also US resident for the purposes of the UK–US double taxation treaty
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The First-tier Tribunal (FTT) determined that a company was entitled in principle to a deduction in computing its rental profits for capitalised revenue expenditure that remained unamortised when the asset to which it related was sold
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The First-tier Tribunal (FTT) held that farmhouse renovation costs were capital in nature and disallowable for income tax purposes
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COSTS - Complex category case - Applications under Rule 10(1)(b) for unreasonable costs and Rule 10(1)(c) for costs following the event - Whether costs to be assessed on the standard or indemnity basis? - 'Costs of and incidental' - Catana and Distinctive Care considered - Interest on costs - Date from which to run, and rate
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Case involving share sale and buy-back transaction, where payment made by the company on the purchase of its own shares was considered by HMRC to be a “distribution” chargeable to income tax under the UK equivalent of s130 TCA 1997
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INCOME TAX– industrial building allowances - buildings ceased to be used by previous owner and sold - new owner intended to let buildings but unable to find a suitable tenant-buildings sold without having been brought back into use -whether or not period of ownership amounted to a period of temporary disuse– ss 271,285 Capital Allowances Act 2001
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The First-tier Tribunal (FTT) found that a disposal of guarantee rights was the disposal of a capital gains tax asset, which did not qualify for UK entrepreneurs’ relief, as the guarantee rights did not constitute “ordinary share capital"
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INCOME TAX and NICs – decision that Appellant self-employed during period of engagement – whether relationship one of employment or self-employment – evidence supports conclusion that Appellant was self-employed – decision affirmed and appeal dismissed
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Transfer of business to Gibraltar - no purpose of avoiding income tax - motive defence - compatibility with EU law
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Partnership established for purposes of constructing a building in Montenegro - claims for sideways loss relief by partners - whether activities of Appellants amounted to a trade – if a trade, whether various payments were trading expenses - basis on which Appellants should calculate any trading loss – application of paragraph 51 of FRS 5 Appellants’ accounts – ss 25, 26, 33, 34 ITTOIA 2005
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