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Kahn and Another v Commissioners of Inland Revenue; In re Toshoku Finance plc: HL 20 Feb 2002

A company went into liquidation, being owed substantial sums by another company in the same group, but itself insolvent. A settlement did not include accrued interest, but was claimed to be taxed as if it had, and on an accruals basis. If so, was this an expense properly arising in the insolvency, and payable as … Continue reading Kahn and Another v Commissioners of Inland Revenue; In re Toshoku Finance plc: HL 20 Feb 2002

RFC 2012 Plc (Formerly The Rangers Football Club Plc) v Advocate General for Scotland: SC 5 Jul 2017

The Court was asked whether an employee’s remuneration is taxable as his or her emoluments or earnings when it is paid to a third party in circumstances in which the employee had no prior entitlement to receive it himself or herself. Held: The company’s appeal failed. The purposive approach to the interpretation of the general … Continue reading RFC 2012 Plc (Formerly The Rangers Football Club Plc) v Advocate General for Scotland: SC 5 Jul 2017

Revenue and Customs v William Grant and Sons Distillers Ltd: HL 28 Mar 2007

The Revenue appealed findings as to the calculation of profits for corporation tax. The companies had sought to deduct sums from profits for depreciation of unsold stock in accordance with current accounting standards. Held: ‘the profit and loss account is concerned with revenue and expenses. A fall in the value of stock to below cost, … Continue reading Revenue and Customs v William Grant and Sons Distillers Ltd: HL 28 Mar 2007

Regina v Inland Revenue Commissioners Ex Parte Banque Internationale a Luxembourg Sa: Admn 23 Jun 2000

The commissioners obtained court orders directing the applicant bank to disclose confidential information in their possession. The bank resisted on the ground that the demand breached their rights to confidentiality and to privacy. Although the orders did infringe the Bank’s article 8 rights, the notices were valid because the interference was justified under article 8(2). … Continue reading Regina v Inland Revenue Commissioners Ex Parte Banque Internationale a Luxembourg Sa: Admn 23 Jun 2000

Regina v Inland Revenue Commissioners Ex Parte Banque Internationale A Luxembourg Sa: QBD 27 Jul 2000

The commissioners obtained court orders directing the applicant bank to disclose confidential information in their possession. The bank resisted on the ground that the demand breached their rights to confidentiality and to privacy. Although the orders did infringe the Bank’s article 8 rights, the notices were valid because the interference was justified under article 8(2). … Continue reading Regina v Inland Revenue Commissioners Ex Parte Banque Internationale A Luxembourg Sa: QBD 27 Jul 2000