RPC Tax Take
For tax professionals on the move
Claim for entrepreneurs' relief succeeds: Tribunal finds that the removal from the payroll did not end taxpayer's employment
The First-tier Tribunal (Tax Chamber) (FTT) has decided in Corbett v HMRC that removing a taxpayer from a company's payroll before a sale of that company did not end her employment for the purposes of claiming entrepreneur's relief.
Mrs Corbett claimed entrepreneurs' relief from capita...
Tribunal rejects Ramsay argument and allows taxpayer's appeal in corporate bond case
In Hancock & Hancock v HMRC the First-tier Tribunal (FTT) has upheld the taxpayer's appeal against HMRC's decision that a chargeable gain arose on the redemption of secured discounted loan notes and rejected HMRC's purposive construction of the relevant legislation.
Mr and Mrs...
Tribunal bars HMRC from taking further part in appeal
In BPP University College of Professional Studies v HMRC the First-tier Tribunal (Tax Chamber) (FTT) found that HMRC had failed to comply with an 'unless' order under Rule 8(3) of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (the Rules).
BPP supplied stand...
First-tier Tribunal holds that there is no taxable supply where there is no obligation on a subsidiary company which was receiving subsidiary services from the Group parent
In Norseman Gold plc v HMRC the First-tier Tribunal (Judge Colin Bishopp) ("FTT") dismissed an appeal by Norseman Gold plc ("Norseman") against assessments made pursuant to section 73 VATA 1994 to recover input tax which had been claimed by it, on the basis that as Norseman had not imposed a char...
Toasted sandwiches are standard-rated “hot food” for VAT purposes
In Sub One Ltd (t/a Subway) v HMRC the Court of Appeal has upheld the decisions of both the First-tier Tribunal (FTT) and the Upper Tribunal (UT) that toasted sandwiches and "meatball marinara" are "hot food" and therefore, for VAT purposes, amount to standard-rated supplies. This decision has im...
Treading uneven boards: VAT claims and setoff – Birmingham Hippodrome Theatre Trust Ltd v HMRC  EWCA Civ 684
The Court of Appeal's decision in this case is likely to create a great deal of uncertainty for taxpayers seeking to recover unlawfully levied VAT from HMRC.
From 1990 to 2004, the Birmingham Hippodrome Theatre Trust charged VAT on the price of tickets to see its productions. VAT was...
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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