Ross Fraser

Ross Fraser Herbert Smith Freehills LLP

Results 1 to 5 of 5

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, Heather Gething.

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, Heather Gething.

UK SDRT charge on an issue of ADRs in respect of shares in a UK company breaches EU law *

United Kingdom - April 3 2012
The recent First tier Tribunal decision in HSBC Holdings and Bank of New York Mellon Corporation v The Commissioners for HMRC contains good news for companies located in Europe seeking to raise capital.

Co-authors: Heather Gething, Howard Murray, Perminder Gainda.

HMRC process for settling tax disputes: updated *

United Kingdom - March 1 2012
An HMRC press release dated 27 February announced more detail on the proposed governance for settlement of major tax disputes.

Co-authors: Heather Gething, Rupert Shiers.

Davies, James and Gaines-Cooper – Supreme Court found HMRC guidance on residence in booklet IR 20, properly construed, did not mean what the taxpayers contended it meant *

United Kingdom - October 28 2011
It was a majority verdict 4 against 1, the leading speech was delivered by Lord Wilson, Lords Hope, Walker and Clarke supporting and Lord Mance dissenting.