The Supreme Court has granted HMRC permission to appeal in both the Deutsche Bank and UBS AG cases, Deloitte has noted. Both cases concerned arrangements to pay bonuses and were unanimously decided in favour of the taxpayers by the Court of Appeal – allowing Deutsche Bank’s appeal against the Upper Tribunal’s decision in favour of HMRC, and dismissing HMRC’s appeal against the Upper Tribunal’s decision in favour of UBS AG. The Supreme Court has also given permission to appeal in the Shop Direct (formerly Littlewoods) case regarding the corporation tax implications of VAT repayments and associated interest.
The Supreme Court has refused permission to appeal in Executors of Lord Howard of Henderskelfe (Deceased) v HMRC (which Deloitte have referred to as the Omai painting ‘plant’ case) as well as in Interfish Ltd v HMRC on the deductibility of sponsorship payments. The HMRC v British Telecommunications Plc case (on BT’s late VAT bad debt relief claim) and the Sub One Limited t/a Subway (in liquidation) v HMRC case (on the VAT treatment of the supply of toasted sandwiches) have also been refused permission to appeal.
The Supreme Court has granted HMRC permission to appeal in both the Deutsche Bank and UBS AG cases, Deloitte has noted. Both cases concerned arrangements to pay bonuses and were unanimously decided in favour of the taxpayers by the Court of Appeal – allowing Deutsche Bank’s appeal against the Upper Tribunal’s decision in favour of HMRC, and dismissing HMRC’s appeal against the Upper Tribunal’s decision in favour of UBS AG. The Supreme Court has also given permission to appeal in the Shop Direct (formerly Littlewoods) case regarding the corporation tax implications of VAT repayments and associated interest.
The Supreme Court has refused permission to appeal in Executors of Lord Howard of Henderskelfe (Deceased) v HMRC (which Deloitte have referred to as the Omai painting ‘plant’ case) as well as in Interfish Ltd v HMRC on the deductibility of sponsorship payments. The HMRC v British Telecommunications Plc case (on BT’s late VAT bad debt relief claim) and the Sub One Limited t/a Subway (in liquidation) v HMRC case (on the VAT treatment of the supply of toasted sandwiches) have also been refused permission to appeal.
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