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Judicial review and tax

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Latest Tax News

Supreme Court rules in Franked Investment Income litigation (Test Claimants in the FII Group Litigation v HMRC)

Supreme Court rules in Franked Investment Income litigation (Test Claimants in the FII Group Litigation v HMRC)

The following Tax news provides comprehensive and up to date legal information on Supreme Court rules in Franked Investment Income litigation (Test Claimants in the FII Group Litigation v HMRC)

SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

The following Private Client news provides comprehensive and up to date legal information on SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

Tax weekly highlights—22 July 2021

Tax weekly highlights—22 July 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—22 July 2021

Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

The following Tax news provides comprehensive and up to date legal information on Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

Featured Tax content

VAT definition

VAT definition

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Capital allowances on property sales—pre-contract enquiries

Capital allowances on property sales—pre-contract enquiries

Capital allowances on property sales—pre-contract enquiriesThis Practice Note is about capital allowance-related pre-contract enquiries on a property...

Two employees have been issued shares and entered into a section 431 election respectively. The date of the signatures is the date the shares are shown at Companies House as being issued. However, where the form requires the date the shares were acquired by the employee, a date has not been inserted. Does this invalidate the section 431 election?

Two employees have been issued shares and entered into a section 431 election respectively. The date of the signatures is the date the shares are shown at Companies House as being issued. However, where the form requires the date the shares were acquired by the employee, a date has not been inserted. Does this invalidate the section 431 election?

Two employees have been issued shares and entered into a section 431 election respectively. The date of the signatures is the date the shares are...

Property authorised investment funds (PAIFs)—summary

Property authorised investment funds (PAIFs)—summary

Property authorised investment funds (PAIFs)—summaryThe regime for property authorised investment funds (PAIFs) was introduced in 2008.It created a...

Practice notes

Share sale or asset sale—tax considerations

Share sale or asset sale—tax considerationsThe sale of a company's business can be structured as either:•a sale of assets owned by the company (an...
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19th May
Practice notes

VAT—triangulation

VAT—triangulationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 19th May
Practice notes

How employment income is taxed—non-cash earnings or benefits

How employment income is taxed—non-cash earnings or benefitsIn addition to cash earnings, such as wages or salaries, many reward packages include...
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19th May
Practice notes

What is an intangible fixed asset?

What is an intangible fixed asset?Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes

UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQs

UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQsWhat are the CDOT agreements?The UK entered into agreements with its three Crown...
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Produced in partnership with Ali Kazimi of Hansuke 19th May
Practice notes

VAT treatment of damages and compensation payments

VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
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19th May
tag iconIn-house
Practice notes

Key tax consequences of an insolvent liquidation

Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
tag iconIn-house
Practice notes

Amortisation of intangible fixed assets

Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes

EIS—deferred gain becomes chargeable to CGT

EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
Practice notes

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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19th May
Practice notes

Offshore receipts in respect of intangible property (ORIP)

Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes

FATCA in the UK—the UK:US Intergovernmental Agreement: an outline

FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
tag iconIn-house
Practice notes

Tax considerations on a loan agreement—the tax gross up clause

Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Precedents

Clause—tax gross up—commercial agreements

1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes

Loan capital exemption from stamp duty

Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes

R&D capital allowances

R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May

Most recent Judicial review and tax content

Practice notes

Judicial review—how to start proceedings

Judicial review—how to start proceedingsThis Practice Note summarises the procedural stages in a judicial review application and then describes in...
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Produced in partnership with Mathew Purchase of Matrix Chambers and Dr Mirza Ahmad of St Philips Chambers 28th Jun
Practice notes

Judicial review in tax cases at the High Court

Judicial review in tax cases at the High CourtThis Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not...
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Produced in partnership with Anne Redston 22nd Jun
Practice notes

Judicial review—what it is and when it can be used

Judicial review—what it is and when it can be usedWhat is judicial review?Judicial review is a process by which the courts exercise a supervisory...
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Produced in partnership with Mathew Purchase of Matrix Chambers and Dr Mirza Ahmad of St Philips Chambers 11th Jun
Q&As

What is the time limit for appealing against a decision of the Upper Tribunal (Tax and Chancery Chamber)? If permission to appeal is allowed, what appellate court would hear the appeal? Is there a way of checking whether an appeal has been lodged?

What is the time limit for appealing against a decision of the Upper Tribunal (Tax and Chancery Chamber)? If permission to appeal is allowed, what...
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6th Jun
Practice notes

Judicial review in the Upper Tribunal

Judicial review in the Upper TribunalThe Tribunals, Courts and Enforcement Act 2007 (TCEA 2007) established the First-tier Tribunal (FTT) and the...
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Produced in partnership with Melanie Carter and Alistair Williams of Bates Wells 5th Jun
Practice notes

An introduction to the Human Rights Act 1998

An introduction to the Human Rights Act 1998Convention rightsThe Human Rights Act 1998 (HRA 1998) came into force in October 2000 and aims to give...
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Produced in partnership with Dr. Alex Williams of Cornerstone Barristers 5th Jun
Q&As

What are considered the leading cases on 'adequate alternative remedy' in judicial review proceedings?

What are considered the leading cases on 'adequate alternative remedy' in judicial review proceedings?Judicial review is considered to be a remedy of...
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Produced in partnership with Jamas Hodivala of Matrix Chambers 5th Jun
Practice notes

Tax and judicial review in the tax tribunals

Tax and judicial review in the tax tribunalsCoronavirus (COVID-19) impact on tribunals: For information on the coronavirus implications for appeals...
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Produced in partnership with Anne Redston 5th Jun

Popular documents

Report on title—long form

Report on title—long form

Property: [insert name and/or address of the Property] (‘Property’)Purchaser: [insert name, address and (if applicable) company registration number of buyer]Transaction: [insert brief details]1Executive summary1.1Scope of reportThis report is addressed to you [insert buyer’s name] and has been

Joint, several, and joint and several liability

Joint, several, and joint and several liability

Joint, several, and joint and several liabilityContractWhere a contract is made by two or more parties it may contain a promise or obligation made by two or more of those parties. Any such promise may be:•joint•several, or•joint and severalWhether an undertaking is joint, several, or joint and

Methods of statutory interpretation used to resolve ambiguities in legislation

Methods of statutory interpretation used to resolve ambiguities in legislation

Methods of statutory interpretation used to resolve ambiguities in legislationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP

Mediation—advantages and disadvantages

Mediation—advantages and disadvantages

Mediation—advantages and disadvantagesWhat is mediation?Mediation is one of the most recognised and common forms of alternative dispute resolution (ADR).It is a form of assisted ADR in the sense that there is a third-party neutral involved who meets with the parties and seeks to help them in