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In this post we consider the recent decision of the High Court in FRC v Frasers Group Plc, a case in which it was held that advice from accountants on a proposed new tax structure was not protected by litigation privilege, even if litigation over the relevant tax affairs was in reasonable contemplation at the time the advice was given. Read more
In March 2020 HMRC released a consultation document regarding a new proposal for legislation requiring large businesses to notify HMRC where they have adopted an “uncertain tax treatment”. This post comprises an abridged version of our response to that consultation, and a link to the full version. Read more
In BlackRock v HMRC (C-231/19), the CJEU held that management services provided by a financial technology services platform for the management of a mix of special investment funds and other investment funds could not benefit from the investment management exemption contained in Article 135(1)(g) of the Principal VAT Directive. Read more
Advocate General Hogan has delivered his opinion in Wellcome Trust Ltd (C-459/19), setting out his view that a "taxable person" who receives services exclusively for the purposes of non-economic activities will nevertheless be treated as a "taxable person" for the purpose of determining the place of supply of those services (for VAT purposes). Read more
The UK government has today announced that the first reporting deadline under DAC 6 will be deferred for 6 months to allow taxpayers and advisors impacted by COVID-19 additional time to comply with their obligations. The first reports under DAC 6 will now be due by 31 January 2021. Read more
A Practice Direction issued by the President of the First-tier Tribunal (Tax) reminds taxpayers to consider whether it may be appropriate to engage with HMRC regarding the use of ADR.
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 Mackay v Wesley [2020] EWHC 1215 (Ch), the Claimant, who was instructed by her father to become a trustee of a family trust as part of a tax scheme, failed to obtain from the High Court (1) an order rescinding her appointment as trustee and/or (2) a declaration that she never became a trustee. 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
