In Fowler, an important case on tax treaty interpretation and the limits of deeming provisions, the Supreme Court determines that the taxpayer could not rely on a deeming provision under UK legislation to escape UK tax on his income under the UK/South Africa tax treaty. The Court of Appeal decides in favour of the taxpayers in NCL Investments that the accounting debits recognised on the grant of share options to their employees by an employee benefit trust were deductible expenses for corporation tax purposes. The Court of Appeal in Investec highlights how complex the taxation of partnerships is, describing HMRC’s approach as ‘work in progress’. The advocate general gives his opinion in the United Biscuits case that supplies of fund management services to defined benefit pension schemes are not within the ‘insurance transaction’ exemption from VAT regardless of whether they are supplied by an insurer or a non-insurer.
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In Fowler, an important case on tax treaty interpretation and the limits of deeming provisions, the Supreme Court determines that the taxpayer could not rely on a deeming provision under UK legislation to escape UK tax on his income under the UK/South Africa tax treaty. The Court of Appeal decides in favour of the taxpayers in NCL Investments that the accounting debits recognised on the grant of share options to their employees by an employee benefit trust were deductible expenses for corporation tax purposes. The Court of Appeal in Investec highlights how complex the taxation of partnerships is, describing HMRC’s approach as ‘work in progress’. The advocate general gives his opinion in the United Biscuits case that supplies of fund management services to defined benefit pension schemes are not within the ‘insurance transaction’ exemption from VAT regardless of whether they are supplied by an insurer or a non-insurer.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
