UPPER-TRIBUNAL

Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.

Peter North

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.

Upper Tribunal cancels inaccuracy penalties

Court of Appeal confirms Martland approach to late appeals

Redress payment taxable as post-cessation receipt

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

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