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...
Depreciatory transactions. Section 176 TCGA 1992 (formerly s.280 TA 1970).The machinery of section 176 (reduction of allowable loss on a disposal of shares in a company if the...
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...
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...
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...
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...
Deductible expenses. Section 74 ICTA 1988. A one-off payment to terminate an onerous contract was deductible in computing profits for corporation tax purposes. The payment was held to...
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...
Notices requiring a third party to produce documents, issued by the Inland Revenue during tax investigations. s.20(3) TMA 1970.The notices were quashed on the grounds (a) that they...
