Supreme Court judgment: Humphreys v HMRC

If you’re in the business of predicting court judgments, you can sometimes end up looking a mug. My last prediction wasn’t the best. Oh, well. At least the judges agreed with me on the time limit. Anyway, while the downside of legal punditry can be a mild judicial mugging from time to time, the upside […]

Humphreys v HMRC: Supreme Court, Day 2

Yesterday I explained the facts and legal background to this case, and a short account of the first day of the hearing, which concluded just after 1 pm today. I was again in court to hear Jason Coppel complete his submissions for HMRC, and Richard Drabble briefly respond. Jason Coppel began by stressing how little […]

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

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 […]

Vodafone 2 v HMRC

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 […]

Charging to the exit?

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! […]