Tag Archives: Corporation Tax
HM Inspector of Taxes -v- Dextra Accessories Ltd; HL 7-Jul-2005
The taxpayer companies had paid funds into a trust for employees. They sought to set off the payments against their liability to corporation tax. The revenue argued that they were deductible only in the year in which they were paid … Continue reading
Filed under Corporation Tax, Taxes management
JD Wetherspoon -v- HMRC; UTTC 31-Jan-2012
UTTC Corporation tax – capital allowances – machinery or plant – conversion, fitting out and refurbishment of public houses – whether items of cost qualify for allowances under section 24 CAA 1990 or section 66 CAA 1990 (or both) – … Continue reading
Filed under Corporation Tax
Shop Direct Group and Others -v- Revenue & Customs; FTTTx 14-Feb-2012
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 … Continue reading
Filed under Corporation Tax
Regina -v- Allen; HL 11-Oct-2001
The defendant appealed against a finding that he had concealed an emolument, namely accommodation. He said that, as a shadow director of the company within the extended meaning of that phrase under the Act, the deeming provisions under income tax … Continue reading
Filed under Company, Corporation Tax, Human Rights, Income Tax, Taxes management
Floor -v- Davis (Inspector of Taxes); CA 1979
The court considered the taxation of a sale of shares in one company called IDM to a company (FNW) and a further sale by that company to a yat another company (KDI). Held(Majority) It was right to look at each … Continue reading
Filed under Corporation Tax
Revenue and Customs -v- The GKN Group; CA 31-Jan-2012
HMRC appealed against an award of interim compensation in the claim by the company for repayment of Advance Corporation Tax.
Filed under 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
