CASES

Share buyback: taxpayer’s Ramsay argument fails before Court of Appeal

Unilateral credit for US withholding tax allowed

SDLT: annuity did not prevent market value rule applying

Intra-group supplies of management charges

Dwelling for SDLT purposesMullane (26 April 2021) is yet another failed claim for SDLT multiple dwellings relief (MDR). This time, the FTT held that a former coach house connected to the main house by a glass conservatory was not suitable for use as...

Danish tax authority faces jurisdictional barrier in withholding tax claim

IBAs were available in period of disuse

Restitution claim on bad debt relief

Whether issue heard as a preliminary matter

Taxation of distributionsIn B Khan v HMRC [2021] EWCA Civ 624 (30 April 2021), the Court of Appeal dismissed the taxpayers appeal and held that the UTs decision was correct. The taxpayer had received a distribution consisting of the...