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Results: 1-10 of 58

Supreme Court applies purposive construction to defeat bank bonus tax avoidance schemes
  • Herbert Smith Freehills LLP
  • United Kingdom
  • March 10 2016

The decision of the Supreme Court in two appeals concerning the effectiveness of bonus arrangements involving allocations of restricted securities to


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


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


HM Revenue & Customs (HMRC) enquiry windowslimitation periods
  • Herbert Smith Freehills LLP
  • United Kingdom
  • April 29 2010

From 1 April 2010, changes introduced by Schedule 39 Finance Act 2008 will take effect and reduce the period within which HMRC can bring an assessment to four years from the end of the accounting period in the case of innocent errors, six years for careless errors and 20 years for deliberate mistakes


ECJ rules that the stamp duty reserve tax charge on entry into a clearance system is illegal under EU law; may have wider implications
  • Herbert Smith Freehills LLP
  • European Union, United Kingdom
  • October 5 2009

In a case last week, HSBC Holdings plc and Vidacos Nominees Ltd v HMRC (C-56907), the European Court of Justice (“ECJ”) held that the 1.5 UK stamp duty reserve tax ("SDRT") charge on the issue of shares into EU clearance systems is illegal


Resolving disputes with HMRC
  • Herbert Smith Freehills LLP
  • United Kingdom
  • July 20 2015

This is the eighth in our series of ADR practical guides, designed to provide clients with essential practical guidance on various processes falling


HMRC wins appeal in penalties for late VAT payments
  • Herbert Smith Freehills LLP
  • United Kingdom
  • January 10 2013

In accordance with the highly prescriptive provisions in the VAT legislation, a company may be in default of a liability to pay VAT if HMRC does not


Autumn Statement 2012
  • Herbert Smith Freehills LLP
  • United Kingdom
  • December 5 2012

Today, the Chancellor of the Exchequer handed down his Autumn Statement


Tax briefing: Pre-budget report 2009
  • Herbert Smith Freehills LLP
  • United Kingdom
  • December 11 2009

This year’s Pre-budget report (PBR), announced in the midst of a serious economic downturn and in a pre-election environment, includes the expected one-off tax charge on bank bonuses amongst other things


Budget measures included in the Finance Act 2010
  • Herbert Smith Freehills LLP
  • United Kingdom
  • April 29 2010

The Chancellor of the Exchequer handed down his Budget on 24 March 2010 and the Finance Act received Royal Assent on 8 April 2010