European Tax

HMRC’s consultation on distributions includes a proposal to scrap a long-standing difference in tax treatment between distributions from...

In the first post in this series, Zoe Andrews described HMRC’s consultation on modernising the taxation of distributions and repayments...

While HMRC’s consultation on modernising the distributions rules looks only at income tax (and not corporation tax) treatment, this post...

Amongst the more (generally) positive proposed changes being considered as part of HMRC's consultation on modernising the distributions...

Never a dull day in Tax! HMRC’s consultation on modernising the taxation of distributions and repayments of capital from companies, which...

The receipt or threat of an information notice from HMRC under Schedule 36 FA 2008 is commonly the point many tax departments reach for...

Can a taxpayer rely on a treaty exemption on the disposal of a shareholding if the gain is not taxed in the taxpayer’s state of...

In a decision of significance for the secondary debt market, the Court of Appeal in Burlington has unanimously dismissed HMRC’s appeal....

When is capital expenditure "on the provision of plant” for the purposes of section 11 Capital Allowances Act 2001? This was the question...

There are many places in the UK tax legislation where deeming provisions are employed in order to apply the tax rules to particular...

The Supreme Court in Hotel La Tour has unanimously rejected the taxpayer’s appeal and determined that the input tax on deal fees...

The November 2025 budget is here at last. During the months of speculation in the run-up to the big day, two possible futures emerged: a...

Amidst the broader UK stamp taxes on shares modernisation efforts (discussed here and here), today in her Autumn Budget 2025, the...

So far, our blog post series on tax disputes in the UK has focussed generally on enquiries and appeals processes. Here, we focus on...

With HMRC statistics showing that HMRC was successful (at least in part) in 93% of First-tier Tribunal (FTT) tax cases in 2024/25, many...

The First-tier Tribunal (FTT) is the first stage of the court process for appealing, for instance, a corporation tax assessment. The...