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HMRC’s approach to settling enquiries and disputes: a positive shift in emphasis
- Herbert Smith Freehills LLP
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- United Kingdom
- -
- July 27 2011
HMRC has published a replacement Litigation and Settlement Strategy (“LSS”) as part of a major review of its approach to disputes
HMRC v Philips Electronics UK Limited
- Herbert Smith Freehills LLP
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- 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
The Government's CFC proposals: in unless you are out
- Herbert Smith Freehills LLP
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- United Kingdom
- -
- July 4 2011
The Government has published the much anticipated consultation document which sets out its latest proposals for the future controlled foreign company (CFC) regime
Corfield: adequate disclosure to prevent discovery assessments
- Herbert Smith Freehills LLP
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- United Kingdom
- -
- August 19 2011
In Corfield, Corfield and Charlton v HMRC, the First-tier Tribunal decided that "discovery" assessments issued by HMRC were not valid because the taxpayers had made adequate disclosure in their returns
Proposals for a UK statutory residence test and changes to the rules applying to non-domiciled individuals to allow remittance to the UK to encourage investment
- Herbert Smith Freehills LLP
- -
- United Kingdom
- -
- June 22 2011
The Government has released the much anticipated consultation documents on the proposals for a statutory residence test (SRT) and reform to the taxation of nondomiciled individuals
"Extreme shopping": HMRC legislation to counter treaty shopping: thoroughly draconian
- Herbert Smith Freehills LLP
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- United Kingdom
- -
- August 5 2011
On 1 August, just before the summer break, HM Revenue & Customs (HMRC) published a "Technical Note" and draft legislation (together, the "Note") entitled "Tax Treaties Anti-avoidance"
HMRC process for settling tax disputes: updated
- Herbert Smith Freehills LLP
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- 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
The draft 2012 Finance Bill
- Herbert Smith Freehills LLP
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- United Kingdom
- -
- December 7 2011
The Government has published Finance Bill 2012 in draft form (the Bill) together with a number of technical notes, responses to consultations held over the summer and other supplementary documents
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
- Herbert Smith Freehills LLP
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- 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
HMRC v Philips Electronics UK Limited
- Herbert Smith Freehills LLP
- -
- European Union, United Kingdom
- -
- April 26 2012
Advocate General’s opinion: UK loss relief rules for branches breach EU law
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