Tax
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PP 2003/33
Rent-factoring scheme – whether lump sum received as income or capital. Q An owner of an investment property, who wishes to raise money without selling or mortgaging the property itself,…
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Inland Revenue Commissioners v John Lewis Properties plc
Respondents assigning chose in action to third party for limited period in return for lump sum — Whether lump sum income or capital receipt for tax purposes
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PP 2002/220
Discrimination against homosexuals: property law implications of Godin-Mendoza v Ghaidan [2002] 46 EG 197 (CS). Q I gather from the Godin-Mendoza decision of the Court of Appeal, as explained in…
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PP 2002/70
Subject to certain financial thresholds, which are fairly high, a lease that provides for one party to make a payment to the other for the carrying out of construction operations…
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Starke and another v Commissioners of Inland Revenue
Buildings used for agricultural purposes — Inheritance tax relief — Relief for agricultural land on pasture including woodlands — Whether agricultural land should have wider meaning to include buildings –…
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Gray (HMIT) v Seymours Garden Centre (Horticulture)
“Planteria” — Structure with suitable conditions for displaying plants in garden centre — Whether planteria was “plant” for purposes of claiming first-year allowances — High Court holding that planteria was…
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Starke and another v Commissioners of Inland Revenue
Buildings used for agricultural purposes — Inheritance tax relief — Relief for agricultural land or pasture including woodlands — Whether agricultural land should have wide meaning to include buildings –…
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Melluish (HMIT) v BMI (No 3) Ltd and others
Lease of equipment — Council premises — Installation of equipment which became fixture — Whether lessor entitled to capital allowances in relation to leasing agreements — Whether equipment belonging to…
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Jarmin (HMIT) v Rawlings
Retirement relief — Sale of farm land and business assets — Whether disposal of whole or part of business — General Commissioners holding taxpayer disposed of dairying part of business…
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Melluish (HMIT) v BMI (No 3) Ltd
Council houses — Installation of central heating — Equipment supplied by taxpayer company under leasing agreements — Ownership remaining with supplier — Writing-down allowances claimed by supplier — Revenue refusing…
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Melluish (HMIT) v BMI (No 3) Ltd and others
Leasing agreements — Lease of equipment — Plant and machinery installed in council premises — Installation of equipment which became fixture — Whether lessor entitled to capital allowances in relation…
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PP 2000/84
“Withholding or deduction on account of tax from payments made under private finance initiatives (PFI) contracts may damage cash flows that underpin projects.