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By Ashurst London
The United Kingdom public have voted to leave the European Union. The next two years will see a period of negotiated withdrawal - with the UK Government deciding which parts of EU law to adopt into domestic legislation.
By Richard Vernon, Darren Rogers
As a leading firm in the built environment industry, we have seen the industry evolve through previous economic and political shockwaves, most notably the effect of the global financial crisis in 2008.
By Crowley Woodford, Annie Morrin, Elizabeth Bayliss, Ruth Buchanan, Sarah-Jane Gemmell
The UK referendum on Brexit took place on 23 June 2016 and, after many months of campaigning from both the Remain and Leave camps, the UK has voted to leave the EU.
By Ashurst London
The First-tier Tribunal has dismissed the taxpayer's appeal against HMRC's decision to disallow a £200m capital loss created by a tax avoidance scheme which relied on the share matching rules in section 106 TCGA 1992.
By Ashurst London
The ECJ has confirmed that in purchasing a portfolio of defaulted receivables, at its own risk, for a price below their face value the transferee, GFKL, was not making a supply of services for consideration.
By Ashurst London
The Court of Appeal (Lloyd, Moses and Etherton LLJ) has issued a further decision in this case, dismissing the entirety of HMRC's appeal in relation to the validity of new non-UK loss relief claims made by Marks & Spencer, the timing of such claims and the quantification of the losses.
By Ashurst London
In a 4-1 majority judgment, the Supreme Court held that HMRC's published guidance on residence should be interpreted as incorporating a test requiring a "distinct break" from the taxpayer's life in the UK.
By Ashurst London
The Upper Tribunal has held that the nondiscrimination article in the UK/US double tax treaty overrode the UK domestic provisions in question (the pre-2000 group relief rules) as these were capable of operating in a cross-border context without the restrictions on the nationality of the parent company which these provisions then contained.
By John Watson, Alexander Cox, Paul Miller, Richard Palmer, Simon Swann
The First Tier Tribunal here looked at a capital gains mitigation scheme involving matching futures and, by construing the legislation purposively and looking at the transactions as a whole, determined that a loss suffered as a result of the reduction in value of shares was not allowable.
By John Watson, Alexander Cox, Paul Miller, Richard Palmer, Simon Swann
HMRC has published two early-stage consultations relating to areas it has identified as high risk. The taxation of unauthorised unit trusts (UUTs) is covered in the first, but the document is mainly focused on obtaining information on the current use of UUTs at this stage.
By John Watson, Alexander Cox, Paul Miller, Richard Palmer, Simon Swann
New rules are proposed to increase the amount of the remittance basis charge in certain circumstances and to allow tax-free remittances for the purposes of investing in qualifying businesses.
By John Watson, Alexander Cox, Paul Miller, Richard Palmer, Simon Swann
The Treasury has published the most detailed proposals yet for the reform of the controlled foreign company (CFC) rules.
By John Watson, Alexander Cox, Paul Miller, Richard Palmer, Simon Swann
The decision of the Upper Tribunal (Tax and Chancery Chamber) to overturn the Tribunal below in the case of BAA Limited, to disallow VAT recovery for certain takeover fees, will have come as an unpleasant surprise to those incurring substantial costs on corporate acquisitions.
By John Watson, Alexander Cox, Paul Miller, Richard Palmer, Simon Swann
Graham Aaronson QC is currently leading a study into the desirability and feasibility of a general anti-avoidance rule (GAAR).
By John Watson, Alexander Cox, Paul Miller, Richard Palmer, Simon Swann
The proposed statutory residence test for individuals is intended to bring some much needed clarity and certainty to this currently vague and complex area.