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In ING Intermediate Holdings Limited –v- HMRC [2017] EWCA Civ 2111, the representative member of the ING VAT group wished to recover a proportion of VAT expenses incurred in connection with a deposit-taking business. In Teoco UK Ltd v Aircom Jersey 4 Ltd and another [2018] EWCA Civ 23, the Court of Appeal dismissed Teoco’s appeal, relating to tax claims brought by Teoco under a share purchase agreement against two Aircom companies. The recent Upper Tribunal decision in Cyclops Electronics Limited and Graceland Fixing Limited v HMRC [2018] UKUT 0007 (TCC) is a post-UBS example of purposive construction being applied to an employee remuneration scheme designed to avoid PAYE and national insurance contributions. The OECD has announced that the Forum on Tax Administration began a pilot of the new International Compliance Assurance Programme (ICAP) on 23 January. ICAP is a voluntary programme for multilateral cooperative risk assessment and assurance.
This article was first published in the 9 February 2018 edition of Tax Journal