First year’s trading relief for losses was ascribable to the year in which the occured not the basis period. Citations: Times 25-Oct-1996 Statutes: Income and Corporation Taxes Act 1988 38(1) Jurisdiction: England and Wales Income Tax Updated: 14 August 2022; Ref: scu.80763
CORPORATION TAX, CAPITAL GAINS TAX, INCOME TAX – expenditure allowable under s38(1)(b) of TCGA 1992 – penalties imposed under s95 of TMA 1970 – interaction of s393A of ICTA 1988, paragraphs 58 and 59 of Schedule 18 FA 1998 and Schedule 1A of TMA 1970 in relation to carry back of losses for corporation tax … Continue reading Hadee Engineering Co Ltd and Others v Revenue and Customs: UTTC 17 Mar 2022
A company is not allowed to allocate set offs of interest payments against foreign income in such a way as merely served with double taxation relief to carry forward the maximum amount of loss. Citations: Times 20-Jan-1999 Statutes: Income and Corporation Taxes Act 1988 338(1) 393(9) 797(3) Jurisdiction: England and Wales Income Tax Updated: 10 … Continue reading Commercial Union Assurance Co Plc v Shaw (Inspector of Taxes): CA 20 Jan 1999
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