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Podcast: Tax News: June 2025 Zoe Andrews and Tanja Velling discuss the Upper Tribunal’s decisions in Walkers Snack Foods on the VAT classification of “Sensations Poppadoms” and Rettig Heating Group, the judicial review of HMRC’s refusal of a late claim to set off a non-trading loan...
Tax treatment of re-domiciliations and cross-border mergers
BLOG: Transfer pricing, permanent establishment and diverted profits tax reform – draft legislation As we previously reported, on 28 April 2025 the UK government announced a technical consultation on draft legislation (the Draft Legislation) to reform the UK’s transfer pricing, permanent establishment (PE) and diverted profits tax (DPT) legislation....
Podcast: Tax News: May 2025 Zoe Andrews and Tanja Velling discuss the First-tier Tribunal’s decisions in: •    Candy giving overpayment relief for an SDLT charge on the substantial performance of a contract that was later cancelled•    Refinitiv on the taxpayer’s...
BLOG: UK tax changes on the horizon How foolish I was for thinking that occasions such as an Autumn Budget or Spring Statement would no longer be followed by a “tax administration and maintenance day” (or TAMD). Admittedly, the current UK government has not used this term, but its “tax...
Tax and the City Review - April 2025 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider: The implications for the insurance industry of the FTT’s decision in Hastings that the UK legislation was ineffective to prevent “offshore looping” of insurance services at the...
Podcast: Tax News: April 2025 Partner Alex Dustan from our Infrastructure and Energy team joined the April 2025 edition of our Tax News podcast to discuss the oil and gas price mechanism consultation on a “new permanent mechanism…to respond to future oil and gas price shocks” once the...
BLOG: UK Spring Statement 2025: No fiscal event, but some developments of interest The UK’s Spring Statement delivered on 26 March 2025 did not include further tax increases and the Chancellor stuck to her commitment to one fiscal event per year – which is going to be the Autumn Statement. Yet, there were more than a few interesting...
Tax and the City Review - March 2025 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider: Lessons on evidence and witness selection from the FTT’s decision in Lloyds Asset Leasing The Supreme Court’s 4:1 split decision in Royal Bank of Canada on the application of...
BLOG: Court of Appeal’s decision in Gunfleet Sands: a boost to the UK government’s infrastructure drive The Court of Appeal published their decision in Gunfleet Sands on 17 March 2025, upholding the taxpayers’ appeal on the availability of capital allowances for predevelopment expenditure on offshore windfarms. This case has previously been referred to as...
Podcast: Tax News: March 2025 In this podcast, tax associate Stephanie Mullins joins Zoe Andrews and Tanja Velling to discuss the UK Supreme Court’s decision in Royal Bank of Canada which could call into question received wisdom on the Ramsay principle of statutory interpretation.
Tax and the City Review - February 2025 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider: the UK Court of Appeal’s decision in ScottishPower that payments in lieu of penalties are tax deductible; HMRC’s supplementary draft guidance on the UK’s implementation of the...
BLOG: Ramsay reined in? Does the dissent in the UK Supreme Court case of Royal Bank of Canada signal changes to statutory construction principles? 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 colleague, Zoe Andrews, has covered the facts and decision in outline here.
BLOG: A question of interpretation: the UK Supreme Court’s decision in Royal Bank of Canada All has ended well for the Royal Bank of Canada (RBC) following the Supreme Court’s majority decision (4:1) that the UK does not have taxing rights over the “royalty” payments RBC received. The value of these payments was dependant on the price and volume...
Podcast: Tax News: February 2025 In this podcast, Tax Associate Nadia Hourihan joins Zoe Andrews and Tanja Velling to discuss the Court of Appeal’s decision in ScottishPower that payments in lieu of penalties are tax deductible (even though no tax deduction would have been available for...