In this article, we consider a recent case which is of considerable interest to tax practitioners given its focus on the income tax consequences of correcting mistakes in bilateral contracts. Read more

In this article we consider the decision of the First-Tier Tribunal to refuse a deduction for management expenses incurred in making a corporate disposal. Read more

In Fowler v HMRC [2020] UKSC 22, the Supreme Court determined that a statutory fiction created by a deeming provision of UK tax law did not affect how the terms of a bilateral tax treaty should be applied. Read more

In The Union Castle Mail Steamship Company Ltd v HMRC & Ors [2020] EWCA Civ 547, the Court of Appeal considered whether corporation tax relief was available for losses arising from the “derecognition” of derivative contracts, required for accounting purposes, on a bonus share issue. Read more

This blogpost considers that announcement, and links to our latest e-bulletins on the changes to off-payroll working rules. Read more

With a Brexit deal still out of reach, the UK government has introduced the Taxation (Cross-border Trade) Act 2018 setting out the customs regime for when the UK finally leaves the European Union.  We consider its provisions and explain how it fits in with wider legislation. Read more

In Littlewoods Ltd and others v HMRC [2017] UKSC 17, the Supreme Court delivered a controversial decision in favour of HMRC, resulting in the failure of the taxpayer's claim for compound interest of £1.2 billion. Read more

This article examines the merits of the current claims against HMRC for repayment of VAT charged on the supply of investment management services to defined benefit pension schemes, and how scheme sponsors might restructure their arrangements in order to secure recovery of VAT on those services (if the current claims against HMRC prove unsuccessful). Read more