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Finance Ltd v HM Inspector of Taxes: SCIT 25 Jan 2005

SCIT CORPORATION TAX – Appellant issued funding bonds to foreign subsidiary companies – whether the effect of section 582 of the Income and Corporation Taxes Act 1988 was to treat the funding bonds as interest and therefore as income with the result that the foreign exchange legislation in the Finance Act 1993 did not apply … Continue reading Finance Ltd v HM Inspector of Taxes: SCIT 25 Jan 2005

HM Revenue and Customs v PA Holdings Ltd: CA 30 Nov 2011

The company made available to certain employees discretionary annual bonuses which were paid instead by way of shares and received dividends. It now appealed against findings that the payments were taxable subject to Schedule F rates and were liable also to National Insurance. Held: Applying White, The court should not be seduced by the form … Continue reading HM Revenue and Customs v PA Holdings Ltd: CA 30 Nov 2011