The Court considered the interpretation of the sections which applied corporation tax to post-cessation receipts. Companies had received from the Inland Revenue substantial repayments of VAT together with interest. There had been reorganisations of the group, the company which had made the overpayment did not exist, and the payee of the repayment had only later … Continue reading Shop Direct Group v Revenue and Customs: SC 17 Feb 2016
The company sought to challenge the assessment to corporation tax of a very large repayment of VAT, together with an even larger amount of interest. Held: The appeal failed. Judges: Rimer, Briggs LJJ, Sir Stanley Burnton Citations: [2014] EWCA Civ 255 Links: Bailii Statutes: Income and Corporation Taxes Act 1988 103 106 Jurisdiction: England and … Continue reading Shop Direct Group v Revenue and Customs: CA 11 Mar 2014
Citations: [2013] EWHC 942 (Ch) Statutes: Income and Corporation Taxes Act 1988 103 106 Jurisdiction: England and Wales Citing: At FTTTx – Shop Direct Group and Others v Revenue and Customs FTTTx 14-Feb-2012 FTTTx Corporation tax – receipts of payments in respect of overpaid VAT and statutory interest – whether VAT repayments trading receipts – … Continue reading Shop Direct Group and Others v HM Revenue and Customs: ChD 19 Apr 2013
FTTTx Corporation tax – receipts of payments in respect of overpaid VAT and statutory interest – whether VAT repayments trading receipts – whether payments in respect of supplies made in discontinued trades chargeable to tax as post-cessation receipts – ICTA 1988, ss 103 and 106(2) – whether payments in respect of interest taxable under Sch … Continue reading Shop Direct Group and Others v Revenue and Customs: FTTTx 14 Feb 2012
UTTC Corporation Tax: Effect of receipt by trader or successor to trade of sums in respect of VAT repaid under s80 VATA to representative member of VAT group plus interest paid under s78 VATA. Question of beneficial ownership of sums received and whether ‘arising from the trade’. Application of sections 103 and 106 ICTA 1988. … Continue reading Shop Direct Group, Littlewoods Retail Ltd and Others v HMRC: UTTC 19 Apr 2013
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