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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.

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

Upper Tribunal rules that pitch hire and league management services was single exempt supply

‘Fishing expedition’ not allowed

Land remediation reliefCompanies which clear contaminated land are, subject to stringent conditions, entitled to an enhanced corporation tax deduction for the costs incurred. One of those conditions is that the contamination was caused by something...

First reported decision on the salaried members rules

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EDITOR'S PICK

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Nick Thornton

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Hartley Foster

Hotel La Tour: where next for input tax recovery on share disposals?

Hotel La Tour: where next for input tax recovery on share disposals?

Rupert Shiers , Laura Hodgson

Mandatory agent registration: what we know so far

Mandatory agent registration: what we know so far

Jane Mellor

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Rob Sharpe , Iarlaith McCarthy-Hann

The Pillar Two Side-by-Side package: how UK groups should approach compliance

The Pillar Two Side-by-Side package: how UK groups should approach compliance

Jack Gifford

Share reorganisations: new anti-avoidance rules explained

Share reorganisations: new anti-avoidance rules explained

Peter Morley , Jamie Robson

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Nick Thornton

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Hartley Foster

Hotel La Tour: where next for input tax recovery on share disposals?

Hotel La Tour: where next for input tax recovery on share disposals?

Rupert Shiers , Laura Hodgson

Mandatory agent registration: what we know so far

Mandatory agent registration: what we know so far

Jane Mellor

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Rob Sharpe , Iarlaith McCarthy-Hann

The Pillar Two Side-by-Side package: how UK groups should approach compliance

The Pillar Two Side-by-Side package: how UK groups should approach compliance

Jack Gifford

Share reorganisations: new anti-avoidance rules explained

Share reorganisations: new anti-avoidance rules explained

Peter Morley , Jamie Robson

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