The Revenue had published a booklet, IR20, setting out their approach to the interpretation of the phrases ‘residence’ and ‘ordinary residence’. The taxpayer said that this was a more generous definition than the statutory one, and that having acted on it he had a legitimate expectation that the booklet’s interpretation would continue to be applied. … Continue reading Davies and Another, Regina (on The Application of) v Revenue and Customs: SC 19 Oct 2011
FTTTx DIRECT TAX – Husband and wife jointly fund share purchase – over 97% shares purchased transferred to husband- new class of shares allotted to wife – wife receives approximately 40% of dividends – whether settlement under s660A ICTA 88. Citations: [2010] UKFTT 334 (TC) Links: Bailii Statutes: Income and Corporation Taxes Act 1988 660A … Continue reading Patmore v Revenue and Customs: FTTTx 14 Jul 2010
Interest relief against tax was allowed to residents in England farming in partnership in Scotland on interest payments on loan. Citations: Times 18-Mar-1998 Statutes: Income and Corporation Taxes Act 1988 353(1) 362(1)(b) Jurisdiction: England and Wales Income Tax Updated: 10 May 2022; Ref: scu.83340
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