CASES

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

UK taxation of a foreign dividend: In J Buckingham v HMRC [2023] UKFTT 358 (TC) (4 April 2023), the taxpayer held shares in the Dr Pepper Group, which was merged with another company using a Delaware special purpose vehicle. A special dividend was...

IR35, partnerships and direct contracts

Upper Tribunal confirms presenter’s services to ITV were within IR35

CJEU distinguishes between the VAT position of local authorities and businesses

Participators’ loan was released when settlement agreement made

Appellant’s grounds of appeal struck out as an abuse of process

Pension liberation scheme: Dalriada Trustees Ltd and others v HMRC [2023] UKFTT 314 (TC) (21 March 2023), is a stark illustration of what can go wrong with pensions liberation schemes and how people caught up in them can end up in in dire financial...

The effect of the option to tax anti-avoidance provisions

LLP profits reallocated via corporate member

Employment agency not liable for tax on supply chain workers, as supply was of excluded services

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