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Carr (Inspector of Taxes) v Armpledge Ltd; Same v Fielden and Ashworth Ltd: ChD 12 Oct 1998

A company’s settlement of its tax affairs had to be dealt with in chronological order even though it would be from it’s point of view more tax efficient to have them dealt with in reverse order. No right of choice was given to a taxpayer. Citations: Times 12-Oct-1998 Statutes: Income and Corporation Taxes Act 1988 … Continue reading Carr (Inspector of Taxes) v Armpledge Ltd; Same v Fielden and Ashworth Ltd: ChD 12 Oct 1998

Piggott (Inspector of Taxes) v Staines Investment Ltd: ChD 1 Mar 1995

An arrangement which had the effect of mitigating tax by a pre-ordained series of steps was nevertheless upheld as valid. Transactions were not caught by anti-avoidance provisions, where they were not in fact one composite whole. Citations: Gazette 01-Mar-1995, Times 07-Feb-1995 Statutes: Income and Corporation Taxes Act 1988 239 Jurisdiction: England and Wales Corporation Tax, … Continue reading Piggott (Inspector of Taxes) v Staines Investment Ltd: ChD 1 Mar 1995

Prudential Assurance Company Ltd v Revenue and Customs: SC 25 Jul 2018

PAC sought to recover excess advance corporation tax paid under a UK system contrary to EU law. It was now agreed that some was repayable but now the quantum. Five issues separated the parties. Issue I: does EU law require the tax credit to be set by reference to the overseas tax actually paid, as … Continue reading Prudential Assurance Company Ltd v Revenue and Customs: SC 25 Jul 2018

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