Taxes Act 1988 ss. 19, 154, 203 and 595 – Appeal allowed.David Goldberg KC and Hugh McKay (instructed by Lawrence Jones) for the taxpayers
This is an astonishing decision. It decides that a role apparently given to the Board of Inland Revenue can be performed by a generally authorised officer who is...
Carry back of surplus ACT and the order in which claims are to be given effect to – s.239(3) ICTA 1988.Decision of Ferris J reversed. The taxpayers were...
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,...
When a company listed on the London Stock Exchange makes a public issue of shares or rights, the issue may be underwritten. The underwriter, for a commission, agrees...
Life Assurance Premium Relief. Reg. 10(6), Income Tax (LAPR) Regulations 1978.Under this system of relief, withdrawn on 13 March 1984, individual policyholders deducted income tax from life assurance...
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....
Statutory interpretation. Carry back of surplus ACT. McGuckian principle applied.The taxpayer was incorporated in 1993. Under Agriculture Act 1993, it was permitted to take over the trade and...
Industrial Buildings Allowance. The taxpayer, which operated cash and carry warehouses, sought to obtain IBAs on the ground that the buildings were used “for the purposes of a...
