HL Income tax, Schedule D – Loss in trade – Dealer in shares – Dividendstripping – Forward-stripping – Whether shares acquired as stock-in-trade – Income Tax Act 1952 (15 and 16 Geo. 6 and 1 Eliz. 2, c. 10), s. 341. Citations: [1966] UKHL TC – 43 – 591, [1966] 1 WLR 1402, [1966] 3 … Continue reading Bishop (Inspector of Taxes) v Finsbury Securities Ltd: HL 26 Jul 1966
Section 402, on its plain meaning, produced results in some cases which were ‘monstrous’ and which Parliament can never have intended. The Commissioners had not sought to amend the legislation, but realising the monstrous result of giving effect to the true construction of the section, worked out what they consider to be an equitable way … Continue reading Bates v Inland Revenue Commissioners: HL 1968
The Court was asked whether and in what circumstances a lower court may follow a decision of the Privy Council which has reached a different conclusion from that of the House of Lords (or the Supreme Court or Court of Appeal) on an earlier occasion. Held: The court set out the position in law and … Continue reading Willers v Joyce and Another (Re: Gubay (Deceased) No 2): SC 20 Jul 2016
Taxpayer companies challenged the way that the revenue restricted claims for group Corporation Tax relief for subsidiary companies in Europe. The issue was awaiting a decision of the European Court. The Revenue said that the claims now being made by other companies should proceed through the Commissioners who could implement European law directly. The taxpayers … Continue reading Autologic Holdings Plc and others v Commissioners of Inland Revenue: HL 28 Jul 2005