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Welcome to October’s edition of our UK Tax Round Up. In the UK, the First-tier Tribunal ruled in Dialog Semiconductor Ltd v HMRC that a $137 million break fee was not a chargeable gain, providing useful guidance on the tax treatment of termination payments. The Upper Tribunal also granted limited permission to appeal in Syngenta Holdings Ltd v HMRC, reopening important questions around the commercial purpose test and apportionment of interest deductions. At the EU level, the Council of the European Union announced its latest revisions to the list of non-cooperative tax jurisdictions, with Vietnam’s removal from Annex II and new commitments made by five jurisdictions to enhance tax transparency.
on October 2025
on October 16, 2025
on September 2025
on October 1, 2025
on August 2025
on July 2025
on June 2025
Welcome to the May edition of our UK Tax Round Up, which discusses two interesting judgments, one on the question of whether a distribution from a Jersey company was of a “capital nature” and the other on whether a loan to a participator in a close company was “released”.
on May 2025
Welcome to April’s edition of our UK Tax Round Up. While this month has been quiet on the case law front, there have been a number of HMRC announcements and updates to prior published guidance along with published responses to consultations covering aspects of the salaried member rules, globally mobile employees, stamp taxes on shares and the permanent establishment, transfer pricing and diverted profits tax rules.
on April 2025
