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Results: 1-10 of 614

Tax - negligence and the burden of proof

  • DMH Stallard LLP
  • -
  • United Kingdom
  • -
  • January 2 2009

When HM Revenue and Customs (HMRC) believe that a taxpayer has understated their income, an assessment is raised to collect the tax which they calculate has been underpaid

Incorrect execution could prove fatal

  • Norton Rose LLP
  • -
  • United Kingdom
  • -
  • August 25 2009

A recent UK decision highlights the importance of finalising and executing documents in the correct manner to ensure the documents cannot later be deemed to be invalid

Execution of contracts

  • RPC
  • -
  • United Kingdom
  • -
  • December 31 2008

Although this is a tax case dealing with the validity of a tax avoidance scheme, it has some interesting things to say about the execution of contracts in general, and the execution of deeds in particular

Administration fees in respect of insurance contracts

  • Mayer Brown LLP
  • -
  • United Kingdom
  • -
  • August 27 2009

The High Court has ruled in the recent case of Homeserve Membership Limited v HM Revenue & Customs that insurance premium tax ("IPT") was not payable on an "arrangement and administration" fee which was separately identified to the customer and which was paid under a separate contract with an insurance intermediary

Ordinary residence: some rare judicial views on the subject

  • Squire Sanders
  • -
  • United Kingdom
  • -
  • April 30 2009

Cases on ordinary residence are extremely rare, so it was interesting to read the decision in Genovese v HMRC SpC 741, in which the very point was examined by the Special Commissioners

Offshore trusts: the Mauritius trust plan succeeds

  • Squire Sanders
  • -
  • Mauritius, United Kingdom
  • -
  • April 30 2009

The High Court have reversed the Special Commissioners’ decision in the case of Smallwood and allowed the taxpayer’s appeal that capital gains made by his trustees in Mauritius were protected by the UKMauritius Double Taxation Agreement

Insurance premium tax chargeable on administration fees

  • Norton Rose LLP
  • -
  • United Kingdom
  • -
  • January 30 2009

There has been a long-running debate as to whether Insurance Premium Tax (IPT) is chargeable on fees which are not payable under the main insurance contract

Between two brokers: Leadx v HMRC

  • Norton Rose LLP
  • -
  • United Kingdom
  • -
  • January 23 2009

A VAT tribunal has ruled that the provision of an internet-based bidding system which allowed brokers to buy and sell leads for potential customers was not within either the insurance or finance-related exemptions from VAT

Recent hearings and developments in the cases

  • Dorsey & Whitney LLP
  • -
  • United Kingdom
  • -
  • February 3 2009

The High Court hearing in the Thin Cap Group Litigation concluded on 30 January

M&S followed in cross border consortium relief claim: Philips v HMRC

  • Dorsey & Whitney LLP
  • -
  • United Kingdom
  • -
  • September 25 2009

A UK subsidiary of non-UK resident link companies sought to claim loss relief from the UK branch of a non-resident subsidiary of the consortium company

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