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Article

DLA Piper | United Kingdom | 2 Apr 2019

SAE Education Ltd -v- HM Revenue & Customs 2019 UKSC 14

A recent decision handed down by the Supreme Court in the case of SAE Education Ltd -v- HM Revenue & Customs 2019 UKSC 14 will be welcomed by

Article

Carey Olsen | USA, United Kingdom | 20 Dec 2018

Offshore limited liability companies and the family office

Often described as a hybrid between a company limited by shares (LTD) and a partnership, limited liability companies (LLCs) are widely regarded as

Article

Stephenson Harwood LLP | United Kingdom | 13 Nov 2018

Barnardo's indexation case: Supreme Court adds another piece to the jigsaw

The Supreme Court has given judgment on the next instalment in the case law determining when pension schemes can switch indices for the purposes of

Article

RPC | United Kingdom | 31 Aug 2018

Feeling Blue? Supreme Court reverses Court of Appeal decision - section 75A gave rise to a notional land transaction with consideration of £1.25bn (more than price paid for the land)

On 13 June 2018, the Supreme Court allowed HMRC's appeal in the long-running case regarding the 2007 sale by the MoD of the Chelsea Barracks. Our

Article

RPC | United Kingdom | 23 Aug 2018

J P Whitter - HMRC not obliged to consider impact of cancellation of Gross Payment Status on business

In J P Whitter (Water Well Engineers) Ltd v HMRC 2018 UKSC 31, the Supreme Court has confirmed the view of the Court of Appeal that HMRC has the

Article

RPC | United Kingdom | 25 Jul 2018

Taylor Clark: Claims for the return of overpaid VAT not to be treated as having been made by or on behalf of the “single taxable person”

In HMRC v Taylor Clark Leisure Plc 2018 UKSC 35, the Supreme Court has held that a company which claimed recovery of VAT is not to be considered to

Article

RPC | United Kingdom | 2 Jul 2018

Project Blue - Supreme Court allows HMRC's appeal in SDLT sub-sale case

In Project Blue Limited v HMRC 2018 UKSC 30, the Supreme Court (by a majority) has found that section 75A, Finance Act 2003 (an anti-avoidance

Article

Squire Patton Boggs | United Kingdom | 20 Jun 2018

SDLT Sub-sale and Sharia-compliant Finance Leaseback Blues: UK Supreme Court's Decision in Project Blue Case

It has been over a decade since the Ministry of Defence (MoD) sold the Chelsea Barracks. Finally, on 13 June 2018, the stamp duty land tax (SDLT)

Article

RPC | United Kingdom | 21 Feb 2018

Business Brief 4 (2017) - HMRC confirms its position following the Supreme Court judgment in Investment Trust Companies

In our April 2017 VAT Update (which can be viewed here) we reported on the Supreme Court's judgment in Investment Trust Companies (in liquidation) v

Article

RPC | United Kingdom | 23 Jan 2018

HMRC issues VAT refund interest guidance following the Littlewoods judgment

On 8 December 2017, HMRC published Revenue & Customs Brief 5 (2017) in which it confirms its position following the Supreme Court's judgment in

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