A tax adjustment can be made by the Inland Revenue on an open assessment following transfer pricing enquiry and direction, even after many years. The court considered that the jurisdiction of the special and the general commissioners to determine such issues was exclusive: ‘It is not easy to discern any clear dividing-line between High Court … Continue reading Glaxo Group Ltd and Others v Inland Revenue Commissioners: ChD 21 Nov 1995
Control of a company within the section means shareholder control. Citations:  STC 785 Statutes: Income and Corporation Taxes Act 1988 416 Jurisdiction: England and Wales Cited by: Cited – Foulser and Another v HM Inspector of Taxes ChD 20-Dec-2005 The taxpayer company entered into an arrangement in which shares were purchased by a company … Continue reading Steele v EVC International NV: 1996
The court considered the taxation of ‘repo’ transactions. The revenue had charged to tax, an element of interest paid on a block og gilts purchased by the taxpayer company under a resale agreement at a price which allowed for the interest payments . .
A scheme involving the use of offshore discretionary trusts resulting in the payment of funds to the directors of the company from which the payments originated was not effective to exclude such payments from liability to tax. Overall the scheme had . .