The taxpayer sought to include in the amounts to be set off by surrender against the group’s liability for corporation tax, chargeable gains in respect of allowable losses of a preceding accounting period. They appealed a decision against them at first instance. Held: The 1988 Act clearly did not allow amounts to be set off … Continue reading Taylor (Inspector of Taxes) v MEPC Holdings Ltd: CA 20 Jun 2002
UTTC CAPITAL GAINS TAX – section 38(1)(b) Taxation of Chargeable Gains Act 1992 – whether expenditure incurred ‘on’ an asset and ‘reflected in the state or nature of the asset at the time of disposal’ – whether expenditure incurred ‘in establishing, preserving or defending title to, or to a right over, the asset Citations: [2015] … Continue reading Revenue and Customs v Blackwell: UTTC 13 Aug 2015
Taxpayer companies challenged the way that the revenue restricted claims for group Corporation Tax relief for subsidiary companies in Europe. The issue was awaiting a decision of the European Court. The Revenue said that the claims now being made by other companies should proceed through the Commissioners who could implement European law directly. The taxpayers … Continue reading Autologic Holdings Plc and others v Commissioners of Inland Revenue: HL 28 Jul 2005
References: [2015] UKUT 418 (TCC) Links: Bailii UTTC CAPITAL GAINS TAX – section 38(1)(b) Taxation of Chargeable Gains Act 1992 – whether expenditure incurred ‘on’ an asset and ‘reflected in the state or nature of the asset at the time of disposal’ – whether expenditure incurred ‘in establishing, preserving or defending title to, or to … Continue reading Revenue and Customs v Blackwell; UTTC 13 Aug 2015
