PARTNERSHIPS

Boulting cannot be regarded as a satisfactory case, except as to its outcome in favour of the taxpayer, writes David Whiscombe.

Redress payment taxable as post-cessation receipt

No entitlement to deductions for amortisation of purchased goodwill

No SDLT due on distributions of partnership and its properties following purchase of JPUT holding structure.

High Court dismisses claim for declaratory relief in relation to failed film partnership scheme

Michael Ridsdale

Gemma Williams

Michael Ridsdale and Gemma Williams (Wedlake Bell) illustrate how to ensure certainty of tax treatment on the structuring of a residential property development.

David Haughey

David Haworth

David Haworth and David Haughey (Freshfields Bruckhaus Deringer) review the implications of the FTT’s decision for those advising on partnership equity/incentivisation arrangements or on mixed member partnership arrangements.

Each week, Tax Journal reports notable judgments on tax issues that have been handed down by the courts and tribunals. This week, we also look back over 2023 and highlight some cases of interest to a wide range of advisers.

Adam Kay

Susan Dennis

The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.

Andrew Howard

Same conclusion but different reasoning. Andrew Howard (Ropes & Gray) reviews the recent Court of Appeal judgment on tiered limited partnerships, profit allocation and interest deductibility.

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