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FTT Decision: Versteegh & Ors v HMRC
...structured to provide a return in the form of preference shares issued by the borrower, not to the lender but to another group company (the share recipient) Lead case issues:...
UT Decision: Cyclops Electronics Ltd/Graceland Fixing Ltd v HMRC
INCOME TAX, NATIONAL INSURANCE CONTRIBUTIONS – award of bonuses in the form of loan notes – whether those loan notes were restricted securities for the purposes of Part 7 ITEPA...
Sheiling Properties Ltd v HMRC; (UT)
Sheiling Properties Limited v HMRC [2020] UKUT 0175 (TCC) Appeal against APN penalties – The Upper Tribunal held that Regulation 80 PAYE determinations can form the basis for an APN....
BlueCrest & Ors v HMRC; (FTT)
...the capital costs of the borrowing could be deducted. The second part of the case concerned an arrangement whereby sum which were expected to form partners’ deferred remuneration were allocated...
FTT Decision: Euroceanica (UK) Ltd v HMRC
Tonnage tax – credits arising from cash collateral – relevant shipping profits – loan relationship credits – whether received in the course of activities forming an integral part of shipping...
R (oao (1) John Boulting (2) PSC Training and Development Group Ltd) v HMRC; (High Court)
...to the clearance procedure. The Court refused permission on the basis that there was a suitable alternative remedy in the form of an appeal to the tribunal, which would be...
UT Decision: Project Blue v HMRC
Stamp Duty Land Tax – Sale and sub-sale of large development site – Application of Finance Act 2003, section 45(3), in the form current in 2007 and 2008 – Sub-sale...
Euromoney v HMRC; (FTT)
...an exchange if the exchange formed part of a scheme or arrangements of which the main purpose, or one of the main purposes, was avoidance of liability to corporation tax,...
R (Haworth) V HMRC; (SC)
...taking into account the severe consequences of follower notices and the intrusion upon the right of access to the courts, the legislation requires that HMRC must form an opinion not...
R (on the application of Sibley) v HMRC; (High Court)
...as to the procedural and formal requirements for applications under the Scheme. To see the approved decision, click here. Ben Elliott (instructed by HMRC) appeared on behalf of the Defendant....
