The Supreme Court has delivered its judgment in Centrica Overseas Holdings. Kyle O’Sullivan (BCLP) reviews the case and its implications.
True story: on the morning of 18 November 2022 I was asked by a client to advise on the potential deductibility of certain transaction fees incurred in respect of a subsidiary which they had sold. After giving my thoughts I had to ring them back later that evening to revise my advice as the Court of Appeal had earlier that day delivered its judgment in HMRC v Centrica Overseas Holdings Ltd [2022] EWCA Civ 1520 overturning the Upper Tribunal’s decision ([2021] UKUT 200 (TCC)) upon which I had heavily relied!
There would have been no repeat scenario on 16 July 2024 when the Supreme Court delivered its judgment on...
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The Supreme Court has delivered its judgment in Centrica Overseas Holdings. Kyle O’Sullivan (BCLP) reviews the case and its implications.
True story: on the morning of 18 November 2022 I was asked by a client to advise on the potential deductibility of certain transaction fees incurred in respect of a subsidiary which they had sold. After giving my thoughts I had to ring them back later that evening to revise my advice as the Court of Appeal had earlier that day delivered its judgment in HMRC v Centrica Overseas Holdings Ltd [2022] EWCA Civ 1520 overturning the Upper Tribunal’s decision ([2021] UKUT 200 (TCC)) upon which I had heavily relied!
There would have been no repeat scenario on 16 July 2024 when the Supreme Court delivered its judgment on...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
