HL Petroleum revenue tax – Tariff receipts from providing the use of a pipeline and other facilities to another oil field – Tariff receipts allowance – Whether allowance to be calculated by reference to the totality of receipts from a user field or each amount separately which is paid for the use of separate qualifying … Continue reading BP Oil Development Ltd v Inland Revenue Commissioners: HL 12 Dec 1991
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Petroleum revenue tax (PRT) – participator in more than one field – whether expenditure incurred on assets to tie-back wells in the first field to a platform in the second field to produce production gases for use in winning oil in the second field is deductible in computing the second field’s profits – Oil Taxation … Continue reading Talisman Energy (UK) Ltd v Revenue and Customs: FTTTx 8 Dec 2009
The claimant alleged complicity by the defendant, (now former) Foreign Secretary, in his mistreatment by the US while held in Libya. He also alleged involvement in his unlawful abduction and removal to Libya, from which had had fled for political persecution. The defendants now appealed from rejection of the defendants’ claim to state immunity and … Continue reading Belhaj and Another v Straw and Others: SC 17 Jan 2017
A British national had been captured in Afghanistan, and was being held without remedy by US forces. His family sought an order requiring the respondent to take greater steps to secure his release or provide other assistance. Held: Such an order would question the legitimacy of the actions of a foreign sovereign state, and to … Continue reading Regina (on the application of Abassi and Another) v Secretary of State for Foreign and Commonwealth Affairs and Another: CA 6 Nov 2002
The court found a contract to be an unconscionable bargain where a poor and illiterate man was induced to enter into a transaction of an unusual nature, without proper independent advice, and in great haste; and the resulting transaction has been, not just hard or improvident, but overreaching and oppressive. Citations: (1862) 4 De GF … Continue reading Clark v Malpas: 25 Apr 1862
The question arose as whether the Inland Revenue were concerned with the provision of services in their activities relating to the adminsitration of the taxation system, so as to bring them within section 20 of the 1976 Act. Held: They were providing services.Templeman LJ said: ‘The Race Relations Act 1976 undoubtedly poses and is continually … Continue reading Savjani v Inland Revenue Commissioners: CA 1981
The taxpayers used schemes to create allowable losses, and now appealed assessment to tax. The schemes involved a series of transactions none of which were a sham, but which had the effect of cancelling each other out. Held: If the true nature of the transactions could be seen by looking at them all together, then … Continue reading W T Ramsay Ltd v Inland Revenue Commissioners: HL 12 Mar 1981
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