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Results: 1-10 of 54

HMRC v Philips Electronics UK Limited
  • Herbert Smith Freehills LLP
  • 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


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


Autumn Statement 2015
  • Herbert Smith Freehills LLP
  • OECD, United Kingdom
  • November 25 2015

The Chancellor of the Exchequer today handed down his Autumn Statement, in combination with the Spending Review. As this is essentially the third


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


Penalty for failure to notify tax avoidance scheme - reliance on counsel's opinion - nil penalty
  • Herbert Smith Freehills LLP
  • United Kingdom
  • March 18 2009

The Special Commissioner in the case of HMRC v Mercury Tax Group Ltd considered (obiter) the penalty to be applied to a taxpayer for a failure to notify a tax avoidance scheme under Part 7 of the Finance Act 2004


"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"


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


UK Supreme Court refuses to extend privilege to accountants
  • Herbert Smith Freehills LLP
  • United Kingdom
  • January 23 2013

The Supreme Court confirmed today that legal advice privilege ("LAP") cannot be claimed in respect of confidential communications between accountants


High Court holds that HMRC disclosure of taxpayer information not unlawful
  • Herbert Smith Freehills LLP
  • United Kingdom
  • November 26 2013

The High Court has ruled that Her Majesty's Revenue and Customs ("HMRC") did not act in breach of confidentiality provisions in disclosing


Autumn Statement 2014 - Autumn leaves its stamp on tax avoidance
  • Herbert Smith Freehills LLP
  • United Kingdom
  • December 4 2014

The Chancellor of the Exchequer yesterday handed down his 2014 Autumn Statement. He made a number of announcements which will impact the UK tax