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Category: David Goldberg KC

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...

Interest. Whether or not “income arising”. Receivability without receipt.The taxpayer opened two deposit accounts with Barclays Bank plc on 12 March 1990, and deposited substantial amounts in them....

The Ramsay principle, as stated in Furniss v. Dawson [1984] STC 153, allows tax legislation to applied to the substance of a transaction. Steps inserted artificially with no...

Mr Sheppard is a stockbroker. In the late 1980’s he incurred legal costs of ¬¨¬£200,000 odd and had to pay a Stock Exchange fine of ¬¨¬£50,000. The costs...

Rectification. Loan documentation: interest clause. Composite rate tax.Both parties to a contract were mistaken as to the tax regime which applied. Section 476(5) ICTA 1988. Crawley Borough Council...

Notices requiring a third party to produce documents, issued by the Inland Revenue during tax investigations. s.20(3) TMA 1970.The draft notices issued by the Revenue in this case...

Capital gains tax. Disposal consideration. Purchaser of company agrees to discharge debt.Spectros disposed of the common stock in its subsidiary SIH. The agreed purchase price was $20,001,000, but...

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