Barnes (HMIT) v Hilton Main Construction: ChD 15 Apr 2005
The revenue had refused to renew the respondent’s certificate, and now itself appealed against the contractor’ success on appeal to the General Commissioners. . .
The revenue had refused to renew the respondent’s certificate, and now itself appealed against the contractor’ success on appeal to the General Commissioners. . .
There was not necessarily subsumed in the concession that a payment constituted an emolument from employment a conclusion that the payment must therefore be for a chargeable period within the aggregate period during which the employment subsisted. . .
References: Ind Summary 22-Feb-1993, (1993) 65 TC 532 Ratio: Income tax was payable under Schedule D on the sale of a builder’s own house. He was shown to have been, in effect, trading taking into account his past record, and doubts about his intention ever to occupy the house as his residence. Some element of … Continue reading Kirkby v Hughes; Chd 22 Feb 1993
References: [2013] UKUT 51 (TCC), FTC/88/2011 Links: Bailii UTTC Income tax – charge on retirement benefits scheme administrator under s591C ICTA 88 on cessation of approval of scheme – whether assessments raised in respect of correct year of assessment – whether raised in the name of correct person. Statutes: Income and Corporation Taxes Act 1988 … Continue reading John Mander Pension Trustees Ltd v Revenue and Customs – FTC/88/2011; UTTC 28 Jan 2013
References: [2012] UKUT 43 (TCC) Links: Bailii UTTC Income Tax; emoluments; tax avoidance scheme; transfer of shares; whether a payment -No; whether shares a readily convertible asset – Yes; Income & Corporation Taxes Act 1988 sections 1, 19, 131, 202A&B, 203, 203A, 203F, The Income Tax (Employments) Regulations 1993 Regulation 2- appeal dismissed Statutes: Income … Continue reading Aberdeen Asset Management Plc v HMRC; UTTC 9 Dec 2011
References: [1991] 1 AC 684 Coram: Lord Templeman The taxpayer was transferred from one football club to another. He was paid £75,000 to persuade him to move. The revenue appealed a decision that this was not a sum taxable as an emolument under Schedule E by the new employer. Held: The appeal was allowed. A … Continue reading Shilton v Wilmshurst: HL 1991
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