RPC Tax Take
For tax professionals on the move
Success for taxpayer before the Supreme Court in pension scheme case
In John Mander Pension Scheme Trusts Limited v Commissioners for Her Majesty's Revenue and Custom's , the Supreme Court has allowed the appellant's appeal holding that the tax charge on withdrawal of approval for a retirement benefits scheme arose in 1996/97, when the scheme ceased to qualify, ra...
Searching Requirements when applying for Search Warrants
The Divisional Court (Davis LJ and Hickinbottom J) has confirmed, in Chatwani, that state agencies applying for search warrants have a duty to make full disclosure to the court and the court should take an inquisitive approach when considering any such application.
The Chatwani br...
Taxpayer's application to have HMRC's winding-up petition dismissed fails due to lack of evidence
In Winnington Networks Communications Ltd v HMRC, the Chancery Division Companies Court (Nicholas Le Poidevin QC) refused the taxpayer company's application to have HMRC's winding-up petitions dismissed, as it had failed to provide evidence that it had a real prospect of successfully disputing th...
Court of Appeal rejects HMRC's appeal and application for a stay in judicial review proceedings
The Court of Appeal (Arden LJ, Black LJ and Floyd LJ) recently confirmed the circumstances in which the Court will exercise its case management powers and grant a stay where a taxpayer is pursuing both an appeal before the First-tier Tribunal ("FTT") and judicial review ("JR") proceedings in the Adm...
High Court dismisses investors' judicial review challenge to the legality of APNs in Rowe and Others v HMRC
The eagerly awaited judgment of the Administrative Court (Mrs Justice Simler) in Nigel Rowe and Others v HMRC, was handed down last Friday. The case concerned a judicial review challenge by a number of investors to the legality of Partner Payment Notices ("PPN's") (a variant of accelerated paymen...
Entrepreneurs' relief not available for disposal of syndicate capacity by a Lloyd's name
In Carver v HMRC  UKFTT 0168 (TC), the First-tier Tribunal (FTT), has provided helpful guidance on the key requirements of entrepreneurs' relief (ER), under section 169H, Taxation of Chargeable Gains Act 1992 (TCGA).
Mr Carver (the Appellant) is an underwriter at Lloyd's (a Llo...
About this blog
Albert Einstein once remarked, on trying to complete his tax return: "This is too difficult for a mathematician. It takes a philosopher!". As tax practitioners are only too well aware, tax legislation continues to increase in length and complexity with the passing of each Finance Act. There is also a steady stream of new case law. Our hope is that, against this background, RPC Tax Take will be a useful source of current information and comment to busy practitioners. It features regular postings on the latest news and developments in UK tax law, together with a number of practical Practice Notes written by specialist lawyers at RPC.
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