The Court of Appeal has handed down its judgment in the Prudential case, in what is hoped to be one of the final steps of this long lasting action between taxpayers invested in cross border portfolio holdings and HMRC. Simon Whitehead and Philippe Freund (Joseph Hage Aaronson), who acted for the taxpayers, summarise the outcome of this judgment and explain why it has taken so long.
Lee Squires and Fiona Bantock (Hogan Lovells) look at recent developments, including: the decisions in Riskstop Consulting and Hedqvist; VAT on pension fund management costs; and the EC consultation on cross-border e-commerce.
Jason Collins (Pinsent Masons) reports on the recommendations in relation to international dispute resolution.
Peter Halford (PwC Legal) considers AG Kokott’s opinion in the ‘Austrian goodwill’ case, including its implications for the Commission’s appeals to the CJEU in the ‘Spanish goodwill’ cases.
Tony Beare (Slaughter and May) examines the recent eagerly anticipated First-tier Tribunal decision of Next Brand Ltd v HMRC on dividend boosters.