Articles
Spring Budget 2024 - Etienne Wong's expert comments
Following the Spring Budget, Etienne Wong commented on the Chancellors announcements which...
British Tax Review: Finance (No 2) Act 2023
Sarah Squires has recently contributed to the British Tax Review Finance Act...
Happy 50th Birthday, VAT! - Tax Journal
Etienne Wong has written an article in the Tax Journal. Please follow...
British Tax Review Issue 5, 2022 - HMRC v Euromoney Institutional Investor Plc
Sarah Squires has contributed to the British Tax Review. HMRC v Euromoney...
British Tax Review: Finance Act 2022 Notes
Sarah Squires has contributed two notes to the recent British Tax Review’s...
Tax Efficient Bequests to Charity
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VAT on the Importation of Excise Goods
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The Tax Journal – VAT in 2021: the ‘teaser year’
Some years start with anticipation – where judgment on an important or...
British Tax Review: Finance Act 2021 Notes
Sarah Squires has contributed to the recent British Tax Review’s Finance Act Notes,...
Trusts and Estates Law & Tax Journal, 2021
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The Tax Journal – Wellcome Trust and the reverse charge
In Wellcome Trust (Case C-459/19), the CJEU held that services supplied to...
‘Forced to continue’ 2021, Tax Adviser
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Wills: which law to interpret a will – a simple question with a complicated answer
Mary Ashley explores a case which illuminates the court’s approach in such...
‘Financial Reporting Council v Frasers Group PLC’ 2021, British Tax Review
https://www.sweetandmaxwell.co.uk/Product/Taxation-Law/British-Tax-Review/Journal/30791232
HMRC v SSE Generation Limited’ 2021, British Tax Review
The procedural importance of the protective assessment. This considers an important capital...
British Tax Review: Finance Act 2020 Notes
Sarah Squires has contributed to the recent British Tax Review’s Finance Act Notes,...
‘Coyle Transport v HMRC’ 2020, British Tax Review
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‘Dong Yang Electronics Case C-547/18’ 2020, British Tax Review
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‘Principal private residence relief’ 2020, Key Haven
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‘Residence under the OECD Model’ 2020, Key Haven
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'The tax plans of the major parties,‘ 2019, Key Haven Tax Review
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The International Aspects of VAT on Legal Advisory Fees
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BlackRock: single supply, dual use – apportionment?
BlackRock (Case C-231/19) concerns VAT on a single supply of investment management...
Royal Opera House: VAT, opera and ice cream
In HMRC v Royal Opera House Covent Garden Foundation, the Upper Tribunal held...
Off-Payroll Working: Treating People Fairly
The Report was published following the Committee’s recent inquiry into the UK...
How to Keep Your Money, Episode 10,’Brexit and Judicial Review’, GFOS (Podcast)
Caroline has been concerned that in recent years new tax legislation has...
The Tax Journal – 2020 through the VAT lens
www.taxjournal.com/home
A stable proposition?’ 2020, Tax Adviser
www.taxadvisermagazine.com/article/stable-proposition
UK Resident Non Doms: The Remittance Basis
The below article by Rebecca Sheldon (barrister at Old Square Tax Chambers)...
‘All bets are off- Fisher v HMRC‘ 2020, Tax Adviser
www.taxadvisermagazine.com/article/all-bets-are
‘Sheiling Properties Limited’ 2020, Tax Adviser
www.taxadvisermagazine.com
Corporation Tax Loss Relief: The Loss Restriction
The Tax Journal recently published part 2 of a practice guide on...
Corporation Tax Loss Relief – Article – Sarah Squires
The Tax Journal recently published a practice guide on corporation tax loss...
‘Italmoda: the birth of the principle of third-party liability for VAT fraud,’ 2016
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‘Finance (No.2) Act 2017 Notes: Section 68: penalty for transactions connected with VAT fraud etc,’ 2017
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‘Praesto Consulting UK Ltd v HMRC [2019] EWCA Civ 353‘ 2019, British Tax Review
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‘All or nothing: Embiricos v Revenue and Customs Commissioners [2019] UKFTT 236 (TC)’ 2019
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British Tax Review: Finance Act 2019 Notes
Sarah Squires is among the contributors to the British Tax Review’s Finance Act...
Limits to Upper Tribunal jurisdiction
Key points Generally, the facts of a case should be determined at...
LexisPSL Practice Note: the QPP exemption – Sarah Squires
Sarah Squires has been recently listed as one of LexisPSL’s contributing authors, following the update of...
Trusts and Estates Law & Tax Journal, 2021
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Trustees’ powers: Beyond the deed
Mary Ashley explores a recent case considering the options by which trustees...
Clauses for Thought (STEP 2018)
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Checking the power – Tax Adviser
The Court of Appeal’s decision in R (on the application of Rowe...
Inheritance tax: The net widens
Mary Ashley discusses the pros and cons of the new inheritance tax...
Imposing Territorial Limitations (Taxation 2017)
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Location Counts (Taxation 2017)
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Variation: Keeping up-to-date
Mary Ashley looks at modernising trusts through variation ‘The court’s jurisdiction does...
A degree of unfairness (Taxation 2016)
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Tax: Victory for the taxpayer
Mary Ashley looks at Lobler v HMRC [2015], which has an interesting...
Surprise Discovery – Tax Adviser, March 2016
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Inheritance Tax: Less tax is more complexity
Mary Ashley takes a look at proposals for the residence nil-rate band...
The Danish GAAR – Defending the Welfare State or Intellectual Inertia?
A comparison of Danish measures against cross-border avoidance with the approach of...
Gifts With Reservation: A win for the taxpayer
Mary Ashley gives an update on the long-running case of Buzzoni v...
Buzzoni v HMRC: another Ingram?
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Trusts: Dealing with mistakes
Mary Ashley examines the lessons from Jersey case In the Matter of...
The December 2012 Amendment of the Corporation Tax Act – A Death Blow for Conduit Companies?
A commentary on an amendment to the Danish Corporation Tax Act, principally...
Measuring the dimensions of the UK Patent Box
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DEEMED DIVIDENDS, ZERO/TEN, JERSEY AND THE EU
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The Transparency of Jersey Partnerships and Certainty when Planning
Harriet’s article is focused on The Transparency of Jersey Partnerships and Certainty...
The Changing Face of Taxation in a Low Tax Jurisdiction
Harriet’s article is focused on theTaxation of Deemed Dividends under Jersey Law:...
Littlewoods Ltd and others v HMRC: compound interest overpaid VAT – where are we now?
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Correcting Mistakes: Ashcroft v Barnsdale and rectification
Please contact chambers by emailing [email protected].
The Development of Hastings-Bass in Jersey
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Queensbury Rules – the HMRC Internal Review Procedure One Year On
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Charities and variation of wills
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Considering the UK Tax Implications for Jersey Foundations
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Income-shifting post Finance Act 2009
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Charitable Changes.
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When is a debt not a debt? The Phizackerley trap
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Inland Revenue certificates
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Tax Avoidance by Transfer of Assets Abroad
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Taxation News, The Charity Law & Practice Review
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FB 2000 & Tax Planning for Offshore Trusts
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Repeal of the Charge on Emigration of Trustees?
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A Case of Uncommon Control: R v. CIR ex p Newfields Developments
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Taxation of E Commerce: A Traditional View
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UK Mini-Budget 2000 Anti Avoidance Measures
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Capital Losses & Trusts
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Transitional Gains & Losses of ‘Golden Trusts’
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Attribution of Capital Gains of Non-Resident Companies
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Private Benefit: A Conundrum
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Value Shifting Out of Shares
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Charities & Imputed Capital Gains
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‘Control’ in the New Transfer Pricing Provisions
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Residence of Companies: The Real Management & Control Test (Company Residence)
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Golden Trusts: Action Prior to 06/04/99
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The Transfer Pricing Provisions & Benefits from Offshore Structures
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‘Where is an Interest in a Unit Trust Situated?
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The Interpretation of Double Taxation Conventions: Residence of Dual Resident & Temporarily Non Resident Individuals
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‘The Source of Interest: A Practical, Hard Matter of Fact’
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A Note on Leon Sartin’s ‘Tax Recovery Claims by the Settlor’
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‘Carbolic Smoke Ball Protects influenza’ or Ingram v. CIR in the HL
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A preface to Julian Ghosh’s ‘Loan Relationships & TCGA 1992 – Conversions.
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Transfers Between Settlements – A Loophole?
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VAT Focus: VAT Groups
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Capital Payments to Charities from Offshore Trusts
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A General Statutory Anti-Avoidance Provision
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CIR v. Challenge Corporation & Ensign Tankers (Leasing) v. Stokes after CIR v. Willoughby
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Corporation Concerns: Meeting Points – the Limitations of Ramsay
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Gifts in Kind to Charity: Some Tax Tips
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The CT Loan Relationships Provisions
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Double Tax Treaty Override: Bricom Holdings v. CIR in the Court of Appeal
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Tax Avoidance After CIR v. Willoughby
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The 100 Year Rule & the Rules Against Perpetuities & Excessive Accumulations
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CIR v. Hang Seng Bank, CIR v. HK-TVB International & CIR v. Orion Caribbean
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CIR v. Challenge Corporation & Ensign Tankers (Leasing) v. Stokes after CIR v. Willoughby
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The Ramsay Doctrine After CIR v. MacGuckian
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Holdover Relief Via Revocable Settlements
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Gifts to Companies: Avoiding the Gift with Reservation of Benefit Provisions
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‘Market Value’: What did CIR v. Crossman Decide?
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Judicial Anti-Avoidance Doctrines After Countess Fitzwilliam
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Offshore Planning: Tax Avoidance After Willoughby v. CIR
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Avoidance Schemes: Tax Planning After McGuckian
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Transfers of Assets Abroad after MacGuckian
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The Bricom Decision – A Reply to Dr. John Avery-Jones from Robert Venables QC
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IR Prosecution: “Unsafe & Unsatisfactory”
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Capital Distributions from Non Resident Trusts: a Tax Trap for Charities
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Partially Exempt Estates & Relieved Property
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‘Unsafe & Unsatisfactory’ – R v. Charlton
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What Did Marshall v. Kerr Decide?
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Double Taxation Treaties: The Antidote to Anti Avoidance Provisions? Bricom Holdings v. CIR
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Capital Distributions from Non Resident Trusts: A Tax Trap for Charities
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Gifts by Associated Operations
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Gift Aid Relief for Gifts in Kind
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Remittances in Kind –A Reply to Richard Bramwell QC
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Company Residence: The New UK Rules
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VAT on the Importation of Excise Goods
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Wills & Their Alternatives in the AIDS Era
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The Insurance & Taxation Implications of Health Trusts
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Taxation of Share Options: A Heterodox Note
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Liability of ‘Donees’ for CGT on Gifts
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Transfer of Assets Abroad: Mr. Brackett’s Problem Case
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Sovereign Immunity & Repayment of Withholding Tax
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Interest in Offshore Funds Held by Non Resident Trustees: FA 1995 Changes
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UK Taxation of Non Residents: The New Substantive Rules
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UK Taxation of Non Residents: Liability of UK Representatives
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An IHT Tax Trap for Settlors of Non Resident Trusts
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The Liechtenstein Foundation & UK Tax Avoidance
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A Note on Gerolstein
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Double Taxation Treaties as a Defence to ICTA 1988, s775-777
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After Marshall v. Kerr
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IHT ‘Traps’ in CGT Planning Schemes
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Gifts of Business Property & Agricultural Property to Discretionary Trusts
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The UK Charity & Double Taxation Treaties
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Personal Portfolio Bonds & ICTA 1988 s.739
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The Offshore Envelope Trick’ – A Problem
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Indirect Demergers – Trust Capital or Income?
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Double Taxation Reg Deathbed Repurchase Ploy
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The Offshore Beneficiary Provisions & Beneficial Loans.
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Moodie v. CIR
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Discretionary Trusts and Reservations of Benefit.
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When a Deed of Variation Does Not Vary.
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When is Remittance Not a Remittance?
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Non Resident Trusts – An IR Setback
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Fundamentals of the Taxation of trustees and beneficiaries – extract from ‘Comments on the IR CD on Taxation of Trusts’
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When is a Settlement the same Settlement?
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GROB Avoidance by Interest in Possession Trust for Spouse
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The Offshore Settlor Provisions – Additions to Non Qualifying Settlements
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Transfer of Assets Abroad – Part 2
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Offshore Trusts: Non Resident Trusts
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Non Residents Trading in the UK
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FB 1991 Offshore Settlor Provisions and Offshore Beneficiaries Provisions
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Variations of Estates, Policy and the Battle of the Books
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CGT Avoidance – the Sub-Subsidiary Trick
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What Did the Second Vestey Case Really Decide?
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