-
Jun 19, 2024 | 
taxjournal.com | Matthew H. Greene |David Whiscombe |Peter Vaines |Johan Barros
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Username *
Password *
Once you have registered, you will receive an email directing you back to read this article in full.
-
Feb 28, 2024 | 
taxjournal.com | Ben Elliott |Sam Glover |Matthew H. Greene |Stuart Pibworth
Home >Articles > Great expectations? VAT and legitimate expectation Great expectations? VAT and legitimate expectation © Copyright LexisNexis 2024. All rights reserved. 28 February 2024 Speed read Recent cases have clarified the circumstances in which the taxpayer has a legitimate expectation in the context of VAT. Such circumstances are now more readily identifiable and, where they arise, taxpayers should be encouraged to bring a claim for judicial review.
-
Feb 7, 2024 | 
taxjournal.com | Matthew H. Greene |Guy Bud |David SMith |David Smith |Richard Johnson
Home >Articles > HMRC’s assessment powers: key considerations HMRC’s assessment powers: key considerations © Copyright LexisNexis 2024. All rights reserved. 7 February 2024 Speed read HMRC’s assessment powers vary depending on the tax at issue but there are common themes.
-
Oct 11, 2023 | 
lexology.com | James Le Gallais |Matthew H. Greene
With mass-marketed tax products back in the spotlight and under HMRC scrutiny, James Le Gallais and Matthew Greene review how HMRC investigates such products and consider what taxpayers should do in response. It is important to note that the HMRC process runs on a separate timetable to any civil claims for compensation a taxpayer may have against the promoters or advisers in relation to the product in question.
-
Sep 7, 2023 | 
taxjournal.com | Matthew H. Greene |Anastasia Nourescu |David Whiscombe |Andrew Levene
Home >Articles > Taxing commodities: reforming the VAT Terminal Markets Order Taxing commodities: reforming the VAT Terminal Markets Order © Copyright LexisNexis 2023. All rights reserved. 7 September 2023 Speed read The government is consulting on a proposed reform of the VAT Terminal Markets Order, which provides for the zero rating of certain commodity transactions on named commodity exchanges.
-
Sep 5, 2023 | 
news.bloombergtax.com | Matthew H. Greene |Pavlos Theodoulou
Most well-advised internationally mobile individuals will be aware of the various day counts that can lead to UK tax residence. Nevertheless, unforeseen emergencies can arise that may cause them to spend more than the allowed number of days in the UK.
-
Sep 5, 2023 | 
lexology.com | Matthew H. Greene
In an article first published in Bloomberg Tax, partner Matthew Greene and senior paralegal Pavlos Theodoulou review the Upper Tribunal’s decision in a recent case providing guidance on the “exceptional circumstances” provision of the statutory residence test in determining UK residency status. Most well-advised internationally mobile individuals will be aware of the various day counts that can lead to UK tax residence.
-
Aug 17, 2023 | 
lexology.com | Matthew H. Greene |Krishna Mahajan |Francesca Bugg
HMRC has had its appeal dismissed in a recent decision by the Upper Tribunal (“UT”), meaning Perenco, an oil and gas producer, will not be liable for £524,000 of petroleum revenue Tax (“PRT”). Matthew Greene, Krishna Mahajan and Francesca Bugg review the recent case of HMRC v Perenco UK Ltd [2023] UKUT 169 (TCC) and its potential implications in a research and development (R&D) relief context.
-
Aug 11, 2023 | 
taxjournal.com | Tom Gilliver |Anastasia Nourescu |Matthew H. Greene |Emma GillZoe Chamberlain
The ‘unallowable purpose’ rule is an anti-avoidance measure thatdisallows tax deductions in respect of payments made under loan relationshipsor derivative contracts, to the extent that such deductions are attributable –using a ‘just and reasonable apportionment’ – to a purpose that is defined as ‘unallowable’.
-
Aug 11, 2023 | 
taxjournal.com | Anastasia Nourescu |Matthew H. Greene |Emma GillZoe Chamberlain |Heather Self
Home >Articles > Other cases that caught our eye: 11 August 2023
Other cases that caught our eye: 11 August 2023
11 August 2023
Lead cases, pensions, discovery, reliance on adviser, surcharges for late VAT payment and more.
Pensions and discovery: There are two distinct points of interest inKillik & Co LLP v HMRC [2023] UKFTT 653 (TC) (25 July 2023). The first relates to in-specie contributions to pension schemes. In Sippchoice [2020] UKUT 149 (TCC), the UT had...
