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Heather Gething Herbert Smith Freehills LLP

Results 6 to 10 of 44



Detailed review of draft Finance Bill 2013 *

United Kingdom - December 18 2012
The provisions of the 2013 Finance Bill have been published in draft form (the draft Bill), together with the explanatory notes and other supplementary documents.

Co-authors: Bradley Phillips, William Arrenberg, Rupert Shiers, Howard Murray, Isaac Zailer.


Autumn Statement 2012 *

United Kingdom - December 5 2012
Today, the Chancellor of the Exchequer handed down his Autumn Statement

Co-authors: Bradley Phillips, William Arrenberg, Neil Warriner, Rupert Shiers, Howard Murray.


HMRC v Philips Electronics UK Limited *

European Union, United Kingdom - September 7 2012
On 6 September 2012 the CJEU delivered a clear ruling in favour of Philips, confirming that the UK provisions which prevent losses of UK branches of non-UK resident companies from being surrendered for group relief (section 107 CTA 2010 condition C, formerly section 403D(1)(c) ICTA 1988) constitute an unjustified restriction of the freedom of establishment under EU law.

Co-authors: Nick Clayton, Rupert Shiers.


Compound interest, portfolio management services, and dividend taxation *

European Union, United Kingdom - July 20 2012
On 19 July 2012 the Court of Justice of the European Union ("CJEU") released judgments in Littlewoods Retail Ltd (and others) v HMRC (Case C-591/10, "Littlewoods") and Finanzamt Frankfurt am Main V-Hochst v Deutsch Bank AG (Case C-44/11, "Deutsche"), and the opinion of Advocate General Jaaskinen in Test Claimants in the FII Group Litigation v HMRC (Case C-35/11, "FII").

Co-authors: Nick Clayton, Ross Fraser.


Tax disputes briefing *

United Kingdom - July 20 2012
From 1973 until October 2004, the taxpayer appellants in Littlewoods overpaid VAT on supplies relating to their catalogue shopping businesses.

Co-authors: Nick Clayton, Ross Fraser.


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