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Category: Conrad McDonnell

Corporation Tax — Two first issues — (1) Was NDSP resident in UK? Held resident outside. (2) Was assessment under section 178 TCGA out of time because section...

Conrad McDonnell appeared for the Appellant

The case concerns directors’ entitlement to draw a pension on early retirement. The taxpayer retired as an executive director (and acting managing director) of the company aged 53,...

Tribunal – procedure – application to strike out – preliminary issues – correct approach – VAT Tribunal Rules 1986, rule 18, rule 19(3)The Tribunal has a wide discretion...

Corporation tax. Accounting periods. ‚ÄúWithin the charge to tax‚Äù Рs.832(1) ICTA 1988.Decision of Court of Appeal (Click here) reversed. ACT paid on a dividend could be carried...

Income tax. Schedule E. PILONs (Payments in Lieu of Notice).

Two employees had notice periods of six months. The contract of employment provided for the contract to be terminated,...

Recent tax cases:

Revenue and Customs v Hotel La Tour Ltd – Court of Appeal
21 May 2024
Lifestyle Equities CV & Anor v Ahmed & Anor – Supreme Court
15 May 2024
Beech Developments (Manchester) Ltd & Ors v Commissioners for His Majesty’s Revenue and Customs – Court of Appeal
09 May 2024
Osmond & Anor v Revenue and Customs – First-tier Tribunal
08 May 2024