The majority of the Court of Appeal in Prudential decides in favour of HMRC that the investment management services are treated as supplied when invoiced (which was after the supplier left the VAT group) rather than when actually made (when part of the VAT group). According to the First-tier Tribunal in Barclays Bank Plc the accounting treatment giving rise to a discount is not GAAP compliant and even if it were GAAP compliant the provision in the accounts does not ‘fairly represent’ a loss arising to the taxpayer from the debt instruments. The Upper Tribunal decides in Beard that payments from the share premium of a non-UK company to a UK shareholder are dividends of an income nature and so subject to income tax. The UK government announces that it will legislate in a future Finance Bill for the global minimum tax country-by-country safe harbour anti-avoidance provision...
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The majority of the Court of Appeal in Prudential decides in favour of HMRC that the investment management services are treated as supplied when invoiced (which was after the supplier left the VAT group) rather than when actually made (when part of the VAT group). According to the First-tier Tribunal in Barclays Bank Plc the accounting treatment giving rise to a discount is not GAAP compliant and even if it were GAAP compliant the provision in the accounts does not ‘fairly represent’ a loss arising to the taxpayer from the debt instruments. The Upper Tribunal decides in Beard that payments from the share premium of a non-UK company to a UK shareholder are dividends of an income nature and so subject to income tax. The UK government announces that it will legislate in a future Finance Bill for the global minimum tax country-by-country safe harbour anti-avoidance provision...
If you are not a subscriber, subscribe now to read this content.
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