‘We are delighted to share with you the first edition of the 1 Crown Office Row Tax Newsletter.
In this issue, we bring you a range of important insights and updates from across the tax team covering the ever-changing landscape of tax law. The newsletter covers a broad range of topics across the work we do, covering significant and interesting cases from 2024.’
1 Crown Office Row, 10th December 2024
Source: www.1cor.com
‘This guide outlines some of the key tax issues to consider when setting up a subsidiary in the UK. It assumes that the subsidiary will be a private company limited by shares, although other legal forms are available.’
OUT-LAW.com, 10th December 2024
Source: www.pinsentmasons.com
‘The Autumn Budget 2024 (“the Budget”) saw history being made as Rachel Reeves, who became our first female Chancellor of the Exchequer, set out arguably the biggest tax changes for a generation, set to raise taxes by £41bn by 2029/30 and said to be part of the Government’s plan to revitalise Britain. In this article, we will summarise the key reforms of the Budget, highlighting those which may be of particular relevance to financial remedy practitioners and their clients.’
Financial Remedies Journal, 1st November 2024
Source: financialremediesjournal.com
‘The off-payroll working rules, known as IR35, apply where a business engages an individual to provide services off-payroll and through an intermediary – commonly a company referred to as a ‘personal services company’ (PSC). IR35 targets the use of PSCs to avoid employment taxes.’
OUT-LAW.com, 13th September 2024
Source: www.pinsentmasons.com
‘This guide considers the tax implications of using a UK holding company to hold shares in other UK or overseas companies.’
OUT-LAW.com, 9th August 2024
Source: www.pinsentmasons.com
‘Tax deductions were not available for professional fees incurred by an investment company once a decision to sell a business it held had been made, because they were expenses of a capital nature even though they are accepted to have been expenses of management, the UK’s highest court has ruled.’
OUT-LAW.com, 31st July 2024
Source: www.pinsentmasons.com
‘A recent English Court of Appeal decision provides food for thought surrounding the use of “incidental” in tax legislation, an expert has said.’
OUT-LAW.com, 12th February 2024
Source: www.pinsentmasons.com
‘HMRC has not charged a single company under landmark legislation passed six years ago to crack down on corporate tax evasion.’
The Guardian, 20th January 2024
Source: www.theguardian.com
‘In this post, Jack Prytherch, Of Counsel in the Tax Disputes & Investigations team at CMS, comments on the Supreme Court’s decision in HMRC v SSE Generation Ltd [2023] UKSC 17, which was handed down on 17 May 2023. The issue before the Supreme Court was the extent to which SSE Generation Ltd (“SSE”) was entitled to claim capital allowances on expenditure incurred when constructing the hydro-electric power station at Glendoe, Fort Augustus in Scotland (the “Glendoe Scheme”). The CMS Tax Disputes & Investigations team was pleased to have advised SSE on this case. Counsel for SSE were Jonathan Peacock KC and Michael Ripley.’
UKSC Blog, 27th June 2023
Source: ukscblog.com
‘SSE Generation Ltd, the respondent, claimed capital allowances on expenditure incurred when constructing a hydro-electric power station at Glendoe, Fort Augustus in Scotland. Such allowances may be deducted from income for the purpose of calculating a company’s trading profits subject to corporation tax. Commissioners for His Majesty’s Revenue and Customs (“HMRC”) disputed certain allowances claimed by SSE for tax years 31 March 2006 to 31 March 2012 on the basis that in their view certain relevant assets did not give rise to allowable expenditure under the Capital Allowances Act 2001 (the “Act”).’
UKSC Blog, 17th May 2023
Source: ukscblog.com
‘Investors behind the construction of two data centres could not claim Enterprise Zone allowances (EZAs) on the expenditure they incurred because it was deemed to have been incurred under a contract entered into outside of the statutory window for claiming the allowances.’
OUT-LAW.com, 11th November 2022
Source: www.pinsentmasons.com
‘A recent UK Supreme Court decision is a reminder of some of the issues that need to be considered when calculating UK corporation tax profits whilst also highlighting the complexity of the UK’s tax system.’
OUT-LAW.com, 15th August 2022
Source: www.pinsentmasons.com
‘In this post, Andre Anthony, a senior associate in the Tax team at CMS, previews the decision awaited from the UK Supreme Court in Commissioners for Her Majesty’s Revenue and Customs v NCL Investments Ltd and another EWCA Civ 663. The appeal was heard by the Supreme Court on 25 and 26 January 2022. The Supreme Court was asked to consider whether accounting debits relating to the grant of share options to employees are a deductible expense for corporation tax purposes.’
UKSC Blog, 21st February 2022
Source: ukscblog.com
‘This year may finally provide the UK chancellor of the exchequer, Rishi Sunak, with an opportunity to develop medium to long-term strategic corporate tax policies.’
OUT-LAW.com, 17th February 2022
Source: www.pinsentmasons.com
‘The Supreme Court has unanimously allowed this appeal concerning the law of limitation.’
UKSC Blog, 23rd July 2021
Source: ukscblog.com
‘The Chancellor of the Exchequer delivered his Budget yesterday afternoon. A number of tax measures were introduced to ease the financial burden on businesses and individuals. Some were simply extensions of short-term tax relief, including a holiday on business rates for 3 months, maintaining the £500,000 SDLT nil-rate band, and a freeze on alcohol and fuel duties. In this update, I focus on some longer-term measures designed to promote a post-Covid rebound.’
Wilberforce Chambers, 4th March 2021
Source: www.wilberforce.co.uk
‘The FII Group Litigation (‘FII’) was established by an Order made on 8 October 2003 with the purpose of determining common or related questions of law arising out of the tax treatment of dividends received by UK resident companies from non-resident subsidiaries. The Test Claimants’ basic allegation was that their tax treatment (under domestic legislation long-since repealed), as compared to that of wholly-resident UK companies, breached TFEU provisions on freedom of establishment and free movement of capital. The Test Claimants therefore sought repayment of tax paid insofar as it was unlawful under EU law; in some cases, dating back to the UK’s accession in 1973.’
Hardwicke Chambers, 24th February 2021
Source: hardwicke.co.uk
‘The Supreme Court has unanimously allowed this long-awaited appeal arising in the course of long-running proceedings known as the Franked Investment Income (“FII”) Group Litigation. The FII Group Litigation brings together many claims concerning the way in which advance corporation tax and corporation tax used to be charged on dividends received by UK-resident companies from non-resident subsidiaries. The respondents to this appeal are claimants within the FII Group Litigation whose cases have been selected to proceed as test claims on certain common issues (“the Test Claimants”). These issues are being determined in phases, with the courts’ decisions affecting not just the other claims within the FII Group Litigation, but potentially also a number of other sets of proceedings brought by corporate taxpayers against the appellant, the Commissioners for Her Majesty’s Revenue and Customs (“HMRC”).’
UKSC Blog, 20th November 2020
Source: ukscblog.com
‘The former owner of BHS has been convicted of evading tax on £2.2m of income he received from buying the failed high-street chain. Instead of paying the tax he knew he owed, Dominic Chappell, 53, spent a fortune on a luxury lifestyle that included a £90,000 yacht, a Bentley Continental car, a Bahamas holiday and some expensive Beretta guns, Southwark Crown Court heard.’
The Independent, 5th November 2020
Source: www.independent.co.uk
‘Two companies have lost their claim for group relief where the surrendering company went into receivership. The Court of Appeal said that when the receivers were appointed the shareholders of the surrendering company lost control, which meant that group relief was denied.’
OUT-LAW.com, 27th February 2019
Source: www.out-law.com
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