In a significant decision, HMRC v Inverclyde Property Renovation LLP and Clackmannanshire Regeneration LLP  UKUT 0161 (TCC), the Upper Tribunal has upheld HMRC’s powers to issue a notice and commence an enquiry into returns submitted by a limited liability partnership (LLP). LLPs are bodies corporate and not partnerships under the LLPA 2000 but (if the LLPs undertake activities with...
One Essex Court is pleased to announce the launch of its new YouTube channel, which can be accessed here. The channel will host recordings of webinars conducted by members of Chambers, which will also be available to view via the new Webinars page on the One Essex Court website: https://www.oeclaw.co.uk/seminars/webinars. For those wishing to receive notifications in relation to new content as it is...
In Union Castle Steamship Ltd v HMRC  EWCA Civ 547, a lead case, the Court of Appeal reached a fundamental decision on the relationship between taxation and accounting profits. In upholding the Upper Tribunal’s decision ([UKUT] 316) that a DOTAS registered, marketed tax avoidance scheme was ineffective, the Court of Appeal dismissed Union Castle’s claim that the issue of shares,...
Jamie Goldsmith QC, James Fox and Ben Zelenka Martin have written a note about the operation of force majeure clauses in the context of COVID-19. It explores: (i) the circumstances in which a party might be able to rely on a force majeure provision; (ii) the impact of COVID-induced supply constraints; and (iii) whether deposits and advance payments would have to be repaid in the event of force majeure....
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