Analysis: Sempra has rewritten law on debt repayment – The Times

Posted July 19th, 2007 in corporation tax, debts, interest, special report by sally

“The House of Lords’ ruling in the Sempra Metals case, while ostensibly about a complicated tax issue, could challenge the foundations of English law on the repayment of debt.”

Full story

The Times, 19th July 2007

Source: www.timesonline.co.uk

Lords defeat could cost Revenue ‘billions’ – The Times

Posted July 18th, 2007 in corporation tax, interest, news by sally

“Revenue & Customs could be forced to repay “billions” of pounds in tax to UK businesses after suffering a devastating defeat in the House of Lords today.”

Full story

The Times, 18th July 2007

Source: www.timesonline.co.uk

Revenue to take more litigious line over tax cases – The Times

Posted June 11th, 2007 in corporation tax, income tax, news, VAT by sally

“Revenue & Customs has officially declared war on tax cheats, telling individuals and businesses hoping for negotiated settlements that it would rather see them in court.”

Full story

The Times, 11th June 2007

Source: www.timesonline.co.uk

Boake Allen Ltd. v. Revenue and Customs Commissioners – Times Law Reports

Posted May 24th, 2007 in corporation tax, double taxation, law reports by sally

Tax statute is not discriminatory

Boake Allen Ltd. v. Revenue and Customs Commissioners

House of Lords

“Section 247 of the Income and Corporation Taxes Act 1988, by denying companies with foreign parents the right to make a group income election allowing a subsidiary company to pay dividends to a parent company free of advance corporation tax, did not infringe the nondiscrimination articles of the double taxation agreements between the United Kingdom and the United States, or between the UK and Japan.”

The Times, 24th May 2007

Source: www.timesonline.co.uk

Please note the Times Law Reports are only available free on Times Online for 21 days from the date of publication.

Revenue and Customs Commissioners v. William Grant & Sons Distillers Ltd.; Small (Inspector of Taxes) v. Mars UK Ltd. – WLR Daily

Posted May 22nd, 2007 in corporation tax, law reports by sally

Revenue and Customs Commissioners v. William Grant & Sons Distillers Ltd.; Small (Inspector of Taxes) v. Mars UK Ltd. [2007] UKHL 15

“Where the taxpayer companies carried forward in their tax computations the element of depreciation in fixed assets that related to production of unsold stock as part of the cost of unsold stocks they did not infringe the prohibition of deductions for the depreciation of capital assets in s 74(1)(f) of the Income and Corporation Taxes Act 1988 (as renumbered by s 144(2) of the Finance Act 1994).”

WLR Daily, 28th March 2007

Source: www.lawreports.co.uk

Please note once a case has been fully reported in one of the ICLR series the corresponding WLR Daily summary is removed.

Commissioners of Revenue and Customs v. William Grant and Sons Distillers Ltd. – Times Law Reports

Posted April 2nd, 2007 in corporation tax, law reports by sally

Computing depreciation of unsold stock for cash.

Commissioners of Revenue and Customs v. William Grant and Sons Distillers Ltd.

“Taxpayer companies that had carried forward that part of the depreciation in fixed assets that related to production of unsold stocks as part of the cost of unsold stocks had not infringed the prohibition in section 74(1)(f) of the Income and Corporation Taxes Act 1988, as renumbered by section 144(2) of the Finance Act 1994, of deductions for the depreciation of capital assets.

The Times, 2nd April 2007

Source: www.timesonline.co.uk

Please note the Times Law Reports are only available free on Times Online for 21 days from the date of publication.