The First-tier Tribunal, having established the facts, determined that the taxpayer had a reasonable excuse for the failure in tax returns
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The First-tier Tribunal held that compensation received by the taxpayer for the mis-selling of an interest rate swap was revenue in nature and therefore taxable as income
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Re Webster [2020] EWHC 2275 (Ch) (Re Webster [2020] EWHC 2275 (Ch) )
The England and Wales High Court determined that it had no jurisdiction to rectify a mistake in a tax return relating to a taxpayer’s charitable giving
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The Court of Appeal upheld the decision of the Upper Tribunal and confirmed that the attribution of notional capital required by s11AA(3)(b) of the Income and Corporation Taxes Act 1988 (ICTA 1988) was in line with the provisions of the double taxation treaty (DTT) between the UK and Ireland
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The First-tier Tribunal rejected a claim for entrepreneurs’ relief, in circumstances where the shares did not have the required voting rights
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UK High Court case, which provides some important additional guidance for purchasers on best practice for making claims under warranty and indemnity provisions in transaction documents
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Case regarding a claim to rectify a contract for services that an individual had entered into
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R&CC v NCL Investments Ltd [2020] EWCA Civ 663 (R&CC v NCL Investments Ltd [2020] EWCA Civ 663 )
The issue on this appeal is whether debits to the profit and loss accounts of the taxpayer companies, required by generally accepted accounting practice and resulting from the grant to their employees by the trustees of an employee benefit scheme of options to acquire shares in the holding company of the group, are allowable as deductions in the computation of their profits for the purposes of corporation tax
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Fowler v HMRC [2020] UKSC 22 (Fowler v HMRC [2020] UKSC 22 )
A deeming provision of UK tax law, that treated the performance of duties of employment as a diver as if they were carrying on of a trade in the UK for income tax purposes, does not change the fact that, for the purposes of the relevant double taxation treaty (“DTT”), that the taxpayer derived “income from an employment"
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The First-tier Tribunal held that a company that was established specifically to administer a property development but that did not own the property and made no profit from the development was still carrying on a business that included construction operations
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