Tax

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  • Consultation on partnership tax changes Restricted access

    Article

    Submitted: 21 May 2013

    The Government has published a consultation on changes it is proposing to two aspects of the tax treatment of partnerships. These changes are aimed at preventing tax loss that arises from disguising employment relationships through LLPs and from arrangements which involve the allocation of partnership profits and losses.

  • Apportioning termination payments Restricted access

    Article

    Submitted: 13 May 2013

    The First Tier Tribunal has suggested that HMRC has a an obligation, which is wider than simply construing the contractual documents concerned, to consider all the surrounding circumstances when considering the correct apportionment of individual elements of a termination payment.

  • Bad debt relief and VAT only invoices Restricted access

    Article

    Submitted: 10 May 2013

    The Court of Session has held that a trader is only entitled to bad debt relief for the relevant VAT fraction of an unpaid invoice, even where that invoice is a VAT only invoice.

  • Payment for arranging the transfer of fund management contract not a capital sum Restricted access

    Article

    Submitted: 08 May 2013

    The First Tier Tribunal has held that an "investment bonus" received by an individual and resulting from arrangements to transfer the fund management business from his former employer to a new fund manager was an income payment subject to income tax and not a capital receipt.

  • The legislative response to the "Cahuzac Scandal" Restricted access

    Article

    Submitted: 08 May 2013

    The French government is proposing tough measures to counter corruption and tax evasion following embarrassing revelations about ministers' offshore accounts.

  • Tribunal warns HMRC over operation of penal PAYE refund rules Restricted access

    Article

    Submitted: 08 May 2013

    The First Tier Tax Tribunal has held that the penal charge under section 222 ITEPA 2003 did not apply where an employee made good to an employer the PAYE more than 90 days after the purported exercise of the relevant option, since the exercise of the option was conditional on repayment of the tax within 30 days and the original exercise, therefore, ineffective.

  • Tax Avoidance in Energy and Infrastructure? Restricted access

    Article

    Submitted: 07 May 2013

    This article discusses the current debate over the amount of UK tax paid by foreign owned multinational companies compared with their level of UK turnover, with a particular focus on the Energy and Infrastructure sector.

  • Seward & Kissel Briefing: FATCA update - final regulations and Cayman IGA negotiations Restricted access

    Article

    Submitted: 07 May 2013

    Overview of recent developments regarding application of FATCA to private investment funds and steps to ensure compliance from 01 January 2014.

  • WHA input VAT scheme held ineffective Restricted access

    Article

    Submitted: 02 May 2013

    The Supreme Court has held that the payment by an insurer (or its claims handler) of repair costs on a vehicle insured against breakdown is third party consideration and does not give the insurer (or claims handler) any right to recover input VAT: WHA Ltd v HMRC

  • Late paid fees and VAT Restricted access

    Article

    Submitted: 30 April 2013

    Late payment of fees for a sports club still amounted to consideration for a supply of services even though a person was denied access to the facilities for the period when the fees were outstanding.

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