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1 month ago | 
lexology.com | Zoe Andrews |Tanja Velling |Stephanie Mullins
Click here to listen to the audioIn this podcast, tax associate Stephanie Mullins joins Zoe Andrews and Tanja Velling to discuss the UK Supreme Court’s decision in Royal Bank of Canada which could call into question received wisdom on the Ramsay principle of statutory interpretation.
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2 months ago | 
taxjournal.com | David Whiscombe |Tanja Velling
UK regulators had investigated failings by several energy providers. The investigations were settled with the imposition of nominal £1 penalties and redress payments totalling around £28m. The nominal penalties were non-deductible for corporation tax purposes. But what about the much more substantial redress payments? That was the question before the Court of Appeal in ScottishPower (SPCL) Ltd and others v HMRC [2025] EWCA Civ 3 (reported in Tax Journal, 24 January 2025).
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2 months ago | 
taxjournal.com | Joshua Stevens |David Whiscombe |Tanja Velling
The materials published alongside the Budget on 30 October 2024 included Introduction of a UK Carbon Border Adjustment Mechanism from January 2027: Government response to the policy design consultation (the ‘Response Document’). This confirms that the UK will introduce a carbon border adjustment mechanism (CBAM) from 1 January 2027.
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Jan 22, 2025 | 
taxjournal.com | Tanja Velling |David Whiscombe
The imposition of an incremental 10% tariff on Chinese goods and new 25% tariffs on Canadian and Mexican goods as envisaged in two Truth Social posts by President Trump on 25 November 2024 was not included among the executive orders signed by Trump on 20 January 2025 the day of his inauguration. But this cannot be taken as a shift in Trump’s policy preferences.
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Jan 15, 2025 | 
taxjournal.com | Tanja Velling |David Whiscombe
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Jan 15, 2025 | 
taxjournal.com | David Whiscombe |Tanja Velling
There’s an iconic scene in Raiders of the Lost Ark in which our hero confronted with a terrifying sword-wielding assassin simply pulls a gun and shoots him dead. The scene came to mind when reading the First-tier Tribunal case of GCH Corporation Ltd and others v HMRC [2024] UKFTT 922 (TC) – a case in which the taxpayers sought (successfully as it turned out) to take advantage of TCGA 1992 s 59A to avoid CGT. Each of the four members of an LLP sold to the LLP an asset pregnant with gain.
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Jan 15, 2025 | 
taxjournal.com | Mike Lane |Zoe Andrews |Tanja Velling |David Whiscombe
The Court of Appeal in Refinitiv Ltd and others v HMRC [2024] EWCA Civ 1412 dismissed the taxpayer’s judicial review claim seeking to quash or declare unlawful a diverted profits tax (DPT) notice. Refinitiv a UK resident company in the Thomson Reuters group had argued that the DPT notice issued by HMRC in 2018 was incompatible with an advance pricing agreement (APA) entered into for the period from 2008 to 2014.
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Jan 8, 2025 | 
taxjournal.com | Tanja Velling |David Whiscombe
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Jan 7, 2025 | 
taxjournal.com | Tanja Velling |David Whiscombe |Giles Hambly
Having just recovered from the usual end of year rush to get policies in place tied to transactions closing (most sellers want to avoid providing an indemnity), I have an exciting variety of risks on my desk, including risks from sub-Saharan Africa, Germany, Turkey, the Middle East and the UK.
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Jan 7, 2025 | 
taxjournal.com | David Whiscombe |Benjamin Wonnacott |Andrew Constable |Tanja Velling
The announcement of a Spring Statement (rather than another Budget) on 26 March 2025 chimes with the promise of ‘predictability, stability and certainty’ in the UK government’s corporate tax roadmap (which had sat uneasily with the surprise announcement of an increase in employers’ NICs at the Autumn Budget). It also delivers on Labour’s commitment to one major fiscal event a year, although the media has already started to speculate whether the Chancellor may have to announce further tax rises.
