DIVIDEND

Two recent cases provide a reminder of the extent to which taxation outcomes can depend on other areas of law and demonstrate that HMRC will not be limited to ‘pure’ tax law arguments on appeal, write Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright).

Irfan Butt

Andrew Seidler

Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.

Adam Craggs

Constantine Christofi

Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision in Marlborough DP Ltd v HMRC that suggests the shortcomings in HMRC’s general approach following Rangers.

Lee Ellis

Cristiana Bulbuc

The Supreme Court has handed down its third judgment in the long-running FII GLO case. Lee Ellis and Cristiana Bulbuc (Stewarts) consider how we got here and what this means for taxpayers with unresolved issues concerning overseas dividend taxation.

Paula Tallon

Siobhan Sellick

Now that Australia and UK have signed their trade agreement, Paula Tallon and Siobhan Sellick (Prosperity Advisers Group) explain what Australian taxes UK companies will encounter when establishing a business presence there.

Helen Cox

Andrew Goldstone

Andrew Goldstone and Helen Cox (Mishcon de Reya) review the latest tax developments that matter affecting private clients.

Paul Howard

Paul Howard (Gabelle) provides this month’s update examining the most significant recent tax developments affecting SMEs.

Andrew Goldstone

Jeffrey Lee

Andrew Goldstone and Jeffrey Lee (Mishcon de Reya) review recent private client tax developments that matter, including the decisions in McQuillan, X-Wind Power, Mabbutt and Shah.

Philippe Freund

Simon Whitehead

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.

Peter Vaines

The changes to the taxation of dividends proposed in the Budget seem to be worthy of rather more attention than they have received, writes Peter Vaines.

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