UPPER-TRIBUNAL

Rob Sharpe

Rob Sharpe and Peter North (Cleary Gottlieb) examine a recent Upper Tribunal ruling on the taxation of stock appreciation rights – a decision that introduces fresh uncertainty for arrangements falling outside ITEPA 2003 Part 7.

Sinisa Butina

Angela Savin

Angela Savin and Sinisa Butina (KPMG) examine the basis of the Upper Tribunal’s reasoning in Scatola and the broader ramifications for taxpayers seeking certainty and finality to their SDLT affairs.

Gary Barnett

Jo Crookshank

This month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons) covers recent decisions on the single/multiple supply rule and the VAT finance intermediation exemption, as well as HMRC’s change of policy on pension scheme costs.

No deduction allowable for provisions in respect of an unfunded unapproved retirement benefit scheme, Court of Appeal rules

Disclosure: principle of reciprocity

UT strikes out appeal against decision on recusal of FTT judge

Mike Lane

Zoe Andrews

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated guidance on share exchanges.

Publishing UT appeal decisions: Historically, decisions by the Upper Tribunal on applications for permission to appeal against decisions of the FTT have not been published. This practice has recently changed following a Practice Note issued by the...

UT overturns FTT finding of deliberate behaviour as error of law.

Hugh Gunson

Hugh Gunson (Charles Russell Speechlys) examines when it is possible to obtain privacy and/or anonymity orders in tax tribunal proceedings in light of a recent Upper Tribunal decision.

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