2/19/2025 1:10:04 PM Ramsay reined in? Does the dissent in the UK Supreme Court case of Royal Bank of Canada signal changes to statutory construction principles? By Kasim Mehmood What do tax lawyers talk about at lunch? In my case, it’s been the UK Supreme Court's majority decision (4:1) in Royal Bank of Canada. My...
12/11/2024 11:32:47 AM Purposive interpretation by the UK Supreme Court in Cobalt Data Centre By Kasim Mehmood In what appears to be a case confined to the application of the now expired capital allowances regime in respect of “enterprise zones”,...
10/30/2024 6:10:40 PM The UK in 2024: an autumn Budget to “fix the foundations” By Tanja Velling Kasim Mehmood The UK’s Autumn 2024 Budget “delivers a large, sustained increase in spending, taxation, and borrowing” according to the Office for...
4/18/2024 3:44:06 PM Hargreaves Property Holdings v HMRC: Ramsay reigns supreme By Kasim Mehmood In Hargreaves Property Holdings Limited v HMRC, the Court of Appeal dismissed the taxpayer’s appeal against the Upper Tribunal’s decision...
11/23/2023 12:13:32 PM R&D Tax in the Autumn Statement 2023: A tale of two regimes By Kasim Mehmood For those, like me, who have been following the ever-changing research and development (R&D) tax relief landscape in the UK over the past...
6/8/2023 3:00:01 PM Hargreaves Property Holdings v HMRC: Beneficial entitlement and “yearly” interest By Kasim Mehmood The Upper Tribunal’s decision is a helpful ‘back-to-basics’ on the nature and purpose of the provisions on withholding tax on interest...
3/15/2023 6:12:22 PM Relief for R&D Expenditure: A Brief Respite or a Change in Strategy? By Kasim Mehmood In what feels like an everchanging landscape of UK tax relief on research and development (R&D) expenditure, Chancellor Jeremy Hunt in...
9/22/2022 9:02:07 AM Acquiring start-ups under the improved R&D regime By Kasim Mehmood On 20 July 2022, the UK Government released draft legislation intended to implement a number of changes to the research and development...
1/29/2021 5:12:45 PM Revised OECD tax treaty guidance as “temporary” COVID-19 travel restrictions continue to impact business operations By Kasim Mehmood The OECD has issued updated guidance on tax treaties and the impact of the COVID-19 pandemic which adopts broadly similar views on...