tax

Gordon’s speech – and law as a stick for governments

September 30, 2009

Gordon Brown’s conference speech yesterday gripped the nation, obviously – if you want to know what I thought of it politically, have a look at my other blog. A couple of constitutional and legal points emerged from it too, though. Obviously, there was his surprising (in the civil service sense – a phrase I may [...]

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Vodafone 2 v HMRC

June 4, 2009

I’m quite interested in the Court of Appeal’s recent decision in this tax case, about Vodafone’s attempt to structure its takeover of Mannesman in the most tax-efficient way, using a Luxembourg-registered holding company to take advantage of lower rates in that country. The issue was whether the British tax legislation on “controlled foreign companies”, designed [...]

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Charging to the exit?

October 12, 2007

Just in case George and Alastair have got you running for the exits clutching your capital gains, there’s an interesting article in Accountancy Age suggesting that the taxman’s system of exit charges on businesses relocating elsewhere in the EU may be an unlawful restriction on freedom of establishment. It sounds a decent argument to me! [...]

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