Category Archives: Corporation Tax
Inland Revenue Commissioners -v- Scottish and Newcastle Breweries Ltd; HL 1982
Expenditure on refurbishment, decor and fittings in hotels was held to be plant though forming part of the setting of the hotels. The House considered the interpretation of undefined expressions in fiscal legislation, such as ‘trade’, ‘income’, ‘office’ and ‘plant’. … Continue reading
Filed under Corporation Tax
Shove (Inspector of Taxes) -v- Lingfield Park 1991 Ltd; ChD 21-Jul-2003
The taxpayer, a race track owner, sought to claim the cost of laying an artificial all-weather race track surface as a capital allowance. The commissioners had found that it retained a separate identity from the grass, requiring maintenance and so … Continue reading
Filed under Corporation Tax
Banco Bilbao Vizcaya Argentaria -v- Administracion General del Estado; ECJ 8-Dec-2011
Free movement of capital – Corporation tax – Convention for the avoidance of double taxation – Prohibition of deducting tax due but not recovered in another Member State
Filed under Corporation Tax, European
Jowett (Inspector of Taxes) -v- O’Neill and Brennan Construction Ltd; ChD 25-Mar-1998
Wynchgate Construction Ltd, an associated company of the taxpayer company, (‘WCL’), commenced a trade in 1994 of providing the services of British construction workers to a contractor operating in Germany. The trade only lasted for about 5 months. WCL discontinued … Continue reading
Filed under Corporation Tax
Revenue & Customs -v- William Grant & Sons Distillers Ltd (Scotland); HL 28-Mar-2007
The Revenue appealed findings as to the calculation of profits for corporation tax. The companies had sought to deduct sums from profits for depreciation of unsold stock in accordance with current accounting standards.Held: ‘the profit and loss account is concerned … Continue reading
Filed under Corporation Tax, Scotland
Revenue and Customs -v- DCC Holdings (UK) Ltd; SC 15-Dec-2010
The taxpayer had entered into a ‘repo’ loan to its bank, agreeing to purchase a block of gilt edged securities, and to resell them at a later date at a fixed figure. The profit and figures included an allowance for … Continue reading
Filed under Corporation Tax
