COURT-OF-APPEAL

Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.

Kyle Rainsford (Addleshaw Goddard) analyses the Court of Appeal’s reasoning on treaty abuse, ‘taking advantage’ and the future interpretation of principal purpose tests.

The Court of Appeal reins in HMRC’s reading of Rangers, confirming that a genuine EBT loan is not taxable earnings, write Dominic Stuttaford and Katharine Wadia (Norton Rose Fulbright).

Mike Lane and Zoe Andrews (Slaughter and May) provide their unique perspective on the impact of recent rulings from the higher courts and the OECD’s latest findings on the UK’s rising tax burden on labour.

Paul Farey (AECOM) assesses how the Supreme Court’s stricter approach narrows the scope for capital allowances on preparatory expenditure.

Capital allowances not available for environmental studies expenditure

Government funding held to be consideration for supplies

Court of Appeal rejects ‘third option’ for employment contracts, but confirms causal link to carelessness before assessment timeframe can be extended

Court of Appeal finds that distributions debited to company’s share premium account were dividends that were not capital in nature