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CASES

Each week we report the tax cases that matter. Tax Journal subscribers have unrestricted access to the full archive, covering hundreds of cases.

FTT decides treaty shopping provision did not apply
Costs deducted from settlement agreement payment were taxable as earnings.
Capital allowances not available on satellite launch costs 
Free services by charity could qualify as business activity.

Share for share treatment available despite tax avoidance purpose.

Payments for pension changes were not ‘from’ employment.
Upper Tribunal overturns FTT on transfer pricing and unallowable purpose
Payment in respect of pension schemeIn E.ON UK plc v HMRC [2022] UKUT 196 (TCC) (19 July 2022), the UT considered whether a payment made to employees in respect of adverse changes to a company pension scheme were derived 'from' employment and...

£1m penalty for DOTAS failure

Upper Tribunal decides Ramsay case in taxpayers’ favour
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