This was an appeal against the High Court decision in Dodika Ltd & Ors v United Luck Group Holdings Limited from August 2020 (see our Tax Blog on this). The case concerns the question of whether the notice given by the buyer to the sellers under a sale and purchase
Katerina Heal
Court of Appeal decides that Jersey companies were UK tax resident
By Katerina Heal & Stephen Pevsner on
In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the UK for tax purposes by reason of being centrally managed and…
UK Budget 2020
By Katerina Heal & Philip Gilliland on
The UK Budget took place on 11 March. In its first post-Brexit Budget with substantial spending announcements, the Treasury wants to continue to ensure the UK remains an attractive and competitive place to invest and do business. We have summarized here the most notable tax changes that will be of interest to our corporate and international client base. Please contact any member of our UK tax group if you have any queries about how this year’s Budget will affect your business.
Simplification of UK Partnership Tax Reporting for Investment Fund Partnerships
By Katerina Heal & Stephen Pevsner on
In the Finance Act 2018, the UK Government enacted a number of changes to the information required in partnership returns that raised the concern of undue and impracticable administrative burden being imposed on UK investment fund partnerships.
The changes covered a number of areas, including requiring a UK partnership that had partnerships amongst its partners and could not identify all of its “indirect partners” to provide computation statements on four bases covering UK resident individuals and companies and non-UK resident individuals and companies. Given that many fund partnerships have other partnerships amongst their investors and that it is likely to be difficult (if possible) to obtain information on all indirect partners, this change will increase the return information that must be provided to HM Revenue & Customs (“HMRC”).