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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,...

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...

Recent tax cases:

Scottish Power (SCPL) Ltd & Ors v HM Revenue and Customs – Upper Tribunal
05 Sep 2023
Killik & Co Llp v Revenue and Customs – First-tier Tribunal (Tax)
25 Jul 2023
Revenue and Customs v Hotel La Tour Ltd – Upper Tribunal
24 Jul 2023
Strachan v Revenue and Customs – First-tier Tribunal (Tax)
05 Jul 2023