HMRC has carried out some spring cleaning on its GAAR guidance. This and other recent developments affecting the City are reviewed by Mark Middleditch (Allen & Overy).
In Eclipse Film Partners No. 35 LLP, the Court of Appeal ruled that the film partnership’s activities did not constitute trading. Chris Bates and Judy Harrison (Norton Rose Fulbright) examine the judgment and consider the consequences
David Whiscombe (BKL Tax) considers the recent Court of Appeal judgment in Eclipse 35.
Bayo Randle (Devereux Chambers) considers techniques to avoid paying the full costs of bundle preparation, pending the Supreme Court appeal in Eclipse 35
The decision of the Upper Tribunal in Eclipse confirmed that the film partnership in that case was not trading. As Chris Bates and Judy Harrison explain, the decision is also important for what it tells us about the Upper Tribunal’s ability to hear appeals.
Helen Lethaby reviews recent developments affecting the City, including draft Finance Bill provisions and recent decisions in Boyle, Eclipse and Versteegh