In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not contain the level of information required
UK Tax
UK Tax Round Up
By Catherine Sear, Robert E. Gaut & Stephen Pevsner on
UK General Tax Developments
HMRC updates guidance on what constitutes “ordinary share capital”
Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this month, HMRC has updated its guidance on what constitutes “ordinary share capital” for the…
Are fixed rate preference shares “ordinary share capital” for entrepreneurs’ relief – more or less certainty?
By Rebecca Wallis & Stephen Pevsner on
There has been another development on the tricky but important subject of whether the rights attaching to preference shares mean that they are or are not ordinary shares for entrepreneurs’ relief (and other tax) purposes.
Recent cases have shown that share with no right to a dividend are ordinary shares.…
UK Budget – Some Key Changes
By Daniella Abel, Robert E. Gaut & Stephen Pevsner on
The UK Budget took place on 29th October. The Chancellor, Philip Hammond, took the opportunity to make a series of targeted changes to the UK’s tax system, some of which had already been announced, but several of which were new and surprising. We have summarized here of the most…
UK Tax Round Up: October 2018
By Catherine Sear, Robert E. Gaut & Stephen Pevsner on
Welcome to the October edition of the Proskauer UK Tax Round Up. It has been a reasonably busy month, with a number of interesting UK cases being reported as well as further clarity from the CJEU in relation to VAT. The Autumn Budget will be presented later today and the…
UK Tax Round Up: September 2018
By Catherine Sear, Robert E. Gaut & Stephen Pevsner on
Welcome to the September edition of the Proskauer UK Tax Round Up. This month has seen a number of interesting tax cases and some clarity on the meaning of ordinary share capital.
UK Tax Round Up: August 2018
By Catherine Sear, Robert E. Gaut & Stephen Pevsner on
Welcome to the August edition of the Proskauer UK Tax Round Up. Not unexpectedly, August has been a quiet month with just a couple of interesting developments.
Finance Bill 2019 – Proposed relaxation of entrepreneurs’ relief rules
By Robert E. Gaut & Rebecca Wallis on
The proposed amendment to entrepreneurs’ relief (“ER”) in Finance Bill 2019 is designed to address one of the outstanding issues with the current law when dilution of a company results in the loss of ER. Under the current rules, a shareholder who has held, for at least 12 months prior…
UK Finance Bill 2019 published – UK commercial property tax regime for non-resident investors to change, but some relief for trading businesses
By Daniella Abel & Robert E. Gaut on
On 6 July 2018 the UK Finance Bill 2019 was published by the UK Government. The draft Finance Bill contains the details of the new regime on taxation of non-UK resident investors in UK real estate that had been proposed in a consultation by HMRC following the November 2017 Budget…
UK Tax Round Up: July 2018
By Catherine Sear, Robert E. Gaut & Stephen Pevsner on
Welcome to the July edition of the Proskauer UK Tax Round Up. It has been a busy month with both the draft Finance Bill 2018-19 being published and various interesting cases being reported.