Tax analysis: The Court of Appeal has found in HMRC’s favour in a long-running case where millions of pounds of tax was at stake. The court dismissed the taxpayer’s appeal and decided that a disregard provision in the derivative contract rules could only apply to a novation between group companies if both companies were subject to the rules. The court allowed HMRC’s cross-appeal and decided that a valid closure notice had not been issued by HMRC when looked at in its objective factual context.
Sign in or take a trial to read the full analysis.
To continue reading this news article, as well as thousands of others like it, sign in to LexisPSL or register for a free trial
EXISTING USER? SIGN IN
TAKE A FREE TRIAL
Take a free trial
Free trials are only available to individuals based in the UK
Complete all the fields above to proceed to the next step.
**Trials are provided to all LexisPSL and LexisLibrary content, excluding Practice Compliance, Practice Management and Risk and Compliance, subscription packages are tailored to your specific needs. To discuss trialling these LexisPSL services please email customer service via our online form. Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason. Trial includes one question to LexisAsk during the length of the trial.
This Practice Note provides an introduction to intercreditor agreements and their key provisions. This Practice Note:•explains the purpose of having an intercreditor agreement and when an intercreditor agreement would be used instead of a deed of priority or subordination deed•provides links to
This Practice Note considers the nature and scope of arbitration agreements with a particular focus on arbitration agreements pursuant to the law of England and Wales, although it also discusses the concept from an international perspective and includes some comparative examples from other
A limited company that proposes to issue redeemable shares must comply with the provisions of the Companies Act 2006 (CA 2006).Why do companies issue redeemable shares?A company may wish to issue redeemable shares so that it has an alternative way to return surplus capital to shareholders without
Brexit: The UK's departure from the EU on exit day ie Friday 31 January 2020 has implications for practitioners dealing with provisions in the CPR relevant to cross border matters, including CPR 5.4C (discussed below). For guidance on the impact of Brexit on the CPR, see Cross border
0330 161 1234
To view our latest legal guidance content,sign-in to Lexis®PSL or register for a free trial.