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Tax Take Blog

Articles: 1-10 of 684

Henkes - FTT has jurisdiction to determine mixed questions of fact and law on application for closure notice

United Kingdom - May 20 2020 In Henkes v HMRC [2020] UKFTT 159 (TC), the First-tier Tribunal (FTT) decided that it has jurisdiction to determine mixed questions of fact and law on…

“Cum-Ex” trades - implications for financial institutions in the UK

United Kingdom - May 18 2020 On 18 March 2020, following its interim ruling that Cum-Ex trading was per se illegal, a German court found two former London-based investment bankers…

Looney - Termination payments were trading receipts

United Kingdom - May 13 2020 In Kieran Looney & Anor v HMRC [2020] UKUT 0119 (TCC), the Upper Tribunal (UT) has dismissed an appeal against the First-tier Tribunal's (FTT)…

Coyle - Upper Tribunal refuses permission to appeal out of time

United Kingdom - May 6 2020 In Michael Coyle t/a Coyle Transport v HMRC [2020] UKUT 0113 (TCC), the Upper Tribunal (UT) set aside the decision of the First-tier Tribunal (FTT)…

Davies - Taxpayers unable to benefit from motive exemption in TOAA or qualify for treaty relief

United Kingdom - April 29 2020 In Andrew Davies & Others v HMRC [2020] UKUT 67 (TCC), the Upper Tribunal (UT) held that the taxpayers did not satisfy the ‘motive exemption’ in the…

Zipvit - Supreme Court considers deduction of input VAT on supplies mistakenly treated as VAT exempt

United Kingdom - April 22 2020 In Zipvit Ltd v HMRC [2020] UKSC 15, the Supreme Court has referred a number of questions to the Court of Justice of the European Union (CJEU)…

COVID-19 - Now is not the time for businesses to be complacent

United Kingdom - April 16 2020 On 31 March 2020, the Crown Prosecution Service (CPS) and National Police Chiefs' Council (NPCC) issued guidance(1) on how investigators and…

Higgs - FTT lacks jurisdiction to disapply the PAYE Regulations

United Kingdom - April 15 2020 In Philip Higgs and Others v HMRC [2020] UKFTT 117 (TC), the First-tier Tribunal (FTT) held that it did not have jurisdiction to determine whether…

COVID-19: Your workforce - furloughing - act to mitigate the risk of exposure to tax evasion offences as scheme could be open to abuse

United Kingdom - April 9 2020 Jim Harra, Chief Executive at HMRC, has informed a Treasury Committee meeting that he expects the government's multi-billion pound employee furlough…

Fisher - TOAA rules not applicable to sale of business from a UK company to a Gibraltar company

United Kingdom - April 8 2020 In S Fisher and Others v HMRC [2020] UKUT 62 (TCC), the Upper Tribunal (UT) allowed the taxpayers' appeals and held that the transfer of assets abroad…