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Results: 1-10 of 60

Policy guidance given by HMRC may give rise to a general legitimate expectation
  • Herbert Smith Freehills LLP
  • United Kingdom
  • July 18 2016

In R (Biffa Waste Services Limited) v the Commissioners for HMRC 2016 EWHC 1444 (Admin), the claimant company ("Biffa") challenged HMRC's


Tax deductibility of corporate interest expense
  • Herbert Smith Freehills LLP
  • OECD, United Kingdom
  • July 18 2016

On 12 May 2016, HM Treasury and HM Revenue & Customs (HMRC) published their second consultation document on the detailed policy design and


Denial of input VAT deduction for failure to identify a connection with VAT fraud Court of Appeal in Mobilx rejects HMRC test of knowledge but requires traders to consider the circumstances of each trade or transaction
  • Herbert Smith Freehills LLP
  • United Kingdom
  • October 18 2010

It was reported on 7 September 2010 that HMRC have identified the first cases of attempted VAT fraud in the wholesale gas and power markets


"Extreme shopping": HMRC legislation to counter treaty shopping: thoroughly draconian
  • Herbert Smith Freehills LLP
  • 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"


Offshore Funds: Is investment via an offshore investment fund objectionable?
  • Herbert Smith Freehills LLP
  • United Kingdom
  • April 14 2016

In this article we compare the different methods of investment following the abolition of exchange control in the early 1980s. We show how offshore


Tax effect of BREXIT - May 2016
  • Herbert Smith Freehills LLP
  • European Union, United Kingdom
  • May 26 2016

This article has been prompted by the current debate and forthcoming referendum in the UK on the UK's membership of the European Union ("EU") and


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
  • 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


Government procurement rules: tax compliance is a factor to be considered
  • Herbert Smith Freehills LLP
  • United Kingdom
  • February 19 2013

The proposed rules require: Suppliers seeking to secure a government contract to self-certify during the selection stage of the procurement process


Retrospective tax legislation: compatible with the European Convention on Human Rights ("ECHR")
  • Herbert Smith Freehills LLP
  • United Kingdom
  • July 31 2015

Retrospective legislation, seeking to close a tax loophole relating to Stamp Duty Land Tax ("SDLT"), did not engage rights under the ECHR to the


Summer budget 2015
  • Herbert Smith Freehills LLP
  • United Kingdom
  • July 9 2015

The Chancellor of the Exchequer yesterday handed down his second Budget of 2015. It was his first Budget without the Liberal Democrats, and