36 Queen Street, London, EC4R 1BN | +44 (0)20 7242 2642
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,...

Corporation tax. Accounting periods. ‚ÄúWithin the charge to tax‚Äù Рs.832(1) ICTA 1988.Decision of Vinelott J (Click here) upheld. ACT paid on a dividend cannot be carried back...

Income tax. Schedule E. PILONs (Payments in Lieu of Notice).Two employees had notice periods of six months. The contract of employment provided for PILONs to be made, saying...

Enterprise zones, Industrial Buildings Allowance. Section 21(1) CAA 1990.Where an enterprise zone building was purchased after first use, and the purchaser claimed industrial buildings allowance for the purchase...

Corporation tax. Accounting periods. ‚Äö√Ñ√∫Within the charge to tax‚Äö√Ñ√π – s.832(1) ICTA 1988.ACT paid on a dividend cannot be carried back and set against an earlier year’s corporation...

Recent tax cases:

Cobalt Data Centre 2 Llp & Anor v Revenue and Customs – Court Of Appeal
31 Oct 2022
Northumbria Healthcare NHS Foundation Trust v Revenue and Customs – Upper Tribunal
06 Oct 2022
Mccabe v The Commissioner for His Majesty’s Revenue and Customs – First-tier Tribunal (Tax)
30 Sep 2022
Cozy Pet Ltd v Revenue and Customs – First-tier Tribunal (Tax)
29 Sep 2022