RPC Tax Take
For tax professionals on the move
Avoidance scheme effective despite HMRC's attempt to rely on Ramsay
In Gemsupa Limited and Consolidated Property Wilmslow Limited v HMRC  UKFTT 0097 (TC), the First-tier Tribunal (Tax Chamber) ("FTT") found that an avoidance scheme designed to avoid corporation tax on chargeable gains on the disposal of properties through the use of share sales and options to ...
Tribunal confirms no penalty for implementing tax avoidance scheme
In the recent case of Herefordshire Property Company Ltd v HMRC1, the First-tier Tribunal (Tax Chamber) ("FTT") allowed the taxpayer's appeal against the imposition by HMRC of a penalty, which was based on an allegation of negligent implementation of a tax planning scheme by the taxpayer.Regular re...
Tribunal finds in favour of property developer who was not trading
In Terrace Hill (Berkeley) Ltd v HMRC, the First-tier Tribunal ("the FTT") rejected HMRC's arguments and concluded that a property developer's activity in relation to the development of an office property was an investment rather than a trading activity and allowed its appeal.
Tax avoidance scheme succeeds before the Upper Tribunal
In Tower Radio Limited and another v HMRC, the taxpayers successfully utilised a scheme which was designed to take advantage of Part 7 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA).
During the periods relevant to this case, no liability to income tax arose under Chapter...
Taxpayer successfully relies on human rights argument to defeat HMRC following the taxation of the same profits twice
The appellant, in Ignatius v HMRC, has successfully fought off an attempt by HMRC to strike out his appeal, by relying on the European Convention on Human Rights ("ECHR").
The appellant, a barrister, was in the "transitional regime" applicable to barristers moving from the "cash" ...
High Court criticises HMRC's conduct and compels it to honour its undertakings
The published judgment in Abbey Forwarding will not make for comfortable reading for HMRC. Having instigated the winding up of a profitable business, which led to the dismissal of 23 employees, and accused innocent directors of fraud, HMRC then withdrew all assessments made against the company a...
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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