№ files_lp_4_process_2_48939
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Appellate court judgment examining whether interest debits arising from intra-group loan notes issued during a corporate acquisition structure may be disallowed for corporation tax purposes on the basis of an unallowable tax-avoidance purpose under the Corporation Tax Act 2009.
Year:
2024
Country:
United Kingdom
City:
London
Court:
Court of Appeal (Civil Division)
Case Number:
CA-2023-002219
Neutral Citation:
[2024] EWCA Civ 652
Lower Tribunal:
Upper Tribunal (Tax and Chancery Chamber) [2023] UKUT 00194 (TCC)
Judges:
Lord Justice Lewison; Lord Justice Newey; Lord Justice Baker
Date of Judgment:
13 June 2024
Hearing Dates:
15–16 May 2024
Appellant:
JTI Acquisition Company (2011) Limited
Respondent:
The Commissioners for His Majesty’s Revenue and Customs
Legal Field:
Tax Law
Subject:
Corporation tax treatment of interest debits and unallowable purpose under section 442 of the Corporation Tax Act 2009
Legislation Referenced:
Corporation Tax Act 2009
Representatives for the Appellant:
Nicola Shaw KC; Harry Winter
Representatives for the Respondents:
Elizabeth Wilson KC; Rebecca Sheldon
Location of Court:
Royal Courts of Justice, Strand, London
Type of Document:
Appellate court judgment
Related Acquisition:
LeTourneau Technologies Inc acquisition by Joy Global Inc group
Price: 8 / 10 USD
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The product description is provided for reference. Actual content and formatting may differ slightly.
Year:
2022
Region / City:
Wales
Topic:
Education
Document Type:
Recruitment Pack
Organization / Institution:
Estyn
Author:
Owen Evans, Her Majesty’s Chief Inspector of Education and Training
Target Audience:
Prospective applicants for the role of Her Majesty’s Inspector of Education and Training
Period of Validity:
Ongoing
Approval Date:
Not specified
Date of Changes:
Not specified
Year:
1975
Region / city:
London
Topic:
Military appointments
Document type:
Regulatory document
Author:
Ministry of Defence
Target audience:
Royal Navy, Royal Marines, British Regular Army, Royal Air Force personnel
Effective period:
Ongoing
Approval date:
27 May 2022
Amendment date:
May 27, 2022
Year:
2023
Jurisdiction:
England and Wales
Case type:
Civil appeal
Court:
Court of Appeal (Civil Division)
Lower court:
High Court of Justice, King’s Bench Division, Administrative Court
Judges:
Lord Justice Newey, Lady Justice Andrews, Lady Justice Falk
Claimants/Appellants:
Hugh Murphy, Winifred Linnett
Defendants/Respondents:
Commissioners for His Majesty’s Revenue and Customs
Hearing date:
20 April 2023
Judgment date:
15 May 2023
Legal issue:
Interpretation of extra-statutory concession ESC B18 and eligibility for UK income tax credit by UK beneficiaries of non-resident trusts
Trust involved:
Charles Street Group Funded Unapproved Retirement Benefit Scheme
Trustees’ residence:
Guernsey
Beneficiaries’ residence:
United Kingdom
Distributions:
£7,329,856.22 to Hugh Murphy, £1,832,464.06 to Winifred Linnett
Period of disputed tax credits:
before 2012-2013
Previous judgment:
Dismissal by Chamberlain J on 13 July 2021
Year:
2015
Region / City:
Gibraltar
Topic:
Civil Engineering, Contract Dispute, Environmental Issues
Document Type:
Court Judgment
Institution:
Court of Appeal (Civil Division)
Author:
Lord Justice Jackson, Lady Justice Gloster, Lord Justice Floyd
Target Audience:
Legal professionals, civil engineers, construction contractors
Period of Validity:
2015
Approval Date:
9 July 2015
Date of Changes:
None
Hearing Dates:
19 May 2015, 20 May 2015, 21 May 2015
Summary:
Legal judgment concerning a dispute between a Spanish construction company and the Government of Gibraltar regarding the termination of a contract for a road construction project around Gibraltar Airport, focusing on issues of contamination, re-design, and approval processes.
Year:
2025
Region / City:
Geneva
Subject:
Basel Convention, Harmonized System, waste classification, World Customs Organization
Document Type:
Report
Organization:
United Nations Environment Programme (UNEP)
Author:
UNEP Secretariat
Target Audience:
Parties to the Basel Convention, World Customs Organization
Period of Validity:
N/A
Approval Date:
N/A
Amendment Date:
N/A
Context:
A report outlining the progress made by the World Customs Organization regarding amendments to the Harmonized System related to the Basel Convention, focusing on waste classification and customs system adjustments.
Year:
2025
Region / City:
Singapore
Topic:
Customs, Inter-Bank GIRO, Payment Procedures
Document Type:
Application Form
Agency / Organization:
Singapore Customs
Author:
Singapore Customs
Target Audience:
Entities with business transactions involving Singapore Customs
Effective Period:
Ongoing
Approval Date:
Not stated
Date of Amendments:
Not stated
Year:
2024
Region / City:
United Kingdom
Topic:
International Trade, Customs, Tariff Regulations
Document Type:
Regulatory Document
Institution:
United Kingdom Government
Author:
HM Revenue & Customs
Target Audience:
Customs authorities, trade professionals
Effective Date:
16th July 2023
Amendment Date:
16th July 2023
Period of Validity:
Indefinite
Date of Approval:
10th December 2024
Note:
Contextual Description
Document type:
General Agency Agreement
Alternate title:
Customs Broker Power of Attorney
Regulatory authority:
Canada Border Services Agency
Governing association:
Canadian International Freight Forwarders Association Inc.
Applicable law:
Laws of Canada and applicable provincial law
Subject matter:
Authorization of customs brokerage services for import and export of goods
Parties:
Importer of Record and licensed Customs Broker
Authorization scope:
Import and export transactions, CBSA compliance, CARM Client Portal access
Sub-agency authorization:
Permitted under the Customs Act
Dispute resolution:
Binding arbitration
Execution requirement:
Original signed copy by authorized officers
Effective date:
As of the date of execution stated in the document
Year:
Not specified
Region / City:
India
Subject:
KYC (Know Your Customer) Requirements for Customs Clearance
Document Type:
Form
Organization / Institution:
FedEx
Author:
Not specified
Target Audience:
Importers/Exporters
Effective Period:
Not specified
Approval Date:
Not specified
Modification Date:
Not specified
Form Reference:
SC-A-020 (Ver 13 – 07/22)
Date:
DD/MM/YYYY
Note:
Unique Entity Number
Singapore Customs’ Bank Account Number:
001-038761-8
Processing Time:
up to 4 weeks
IBG Termination:
Bank directly
Fee for Unsuccessful IBG Deduction:
Penalty may apply
Contact Email:
[email protected]
Year:
2020
Region / city:
UK
Topic:
Customs declarations
Document type:
API documentation
Organization / institution:
HMRC
Author:
MCP/CNS
Target audience:
Developers, software houses, CSPs
Effective period:
February 2020 – ongoing
Approval date:
February 2020
Modification date:
May 2020, June 2020
Year:
2021
Region / city:
Global
Subject:
Customs codes, mercury-added products
Document type:
Guidance document
Organization / institution:
Minamata Convention Secretariat
Author:
Minamata Convention Secretariat
Target audience:
National experts, stakeholders, and Parties to the Minamata Convention
Period of validity:
Not specified
Date of approval:
Not specified
Date of amendments:
Not specified
Context description:
This document is a guidance on the use of customs codes to monitor the import and export of mercury-added products in accordance with the Minamata Convention.
Year:
2019
Region / City:
United Kingdom
Topic:
Customs Declaration, Aggregated Declarations
Document Type:
Procedure Manual / Technical Scenario
Organization / Institution:
HM Revenue & Customs
Author:
Not specified
Target Audience:
Importers, Declarants, AEO certified traders
Procedure Code:
40 71
Additional Procedure:
000
Declaration Category:
H1
Additional Declaration Type:
Z
Trader EORI Number:
GB025115100001
Importer Recognition:
AEOC
Commodity Code:
420212190050
DUCR Aggregation:
Yes
Warehouse Identification:
U1234567GB
Exporter:
Bags Exports, 1 Bags Avenue, New York, US, NY1 234
Country:
Switzerland
Authority:
Swiss Customs
Legal system:
Civil law
Subject matter:
Legal framework for electronic trade documentation
Document type:
Questionnaire response / policy input
Scope:
Trans-boundary trade procedures
Relevant legislation:
Customs Law (ZG); Customs Ordinance (ZV); Customs Ordinance EZV (ZV-EZV)
International context:
International trade agreements
Implementation timeframe (customs law):
2–2.5 years
Implementation timeframe (international agreements):
1–3 years
Implementation timeframe (ordinances):
Approximately 1 year
Private sector involvement:
Consultation and joint procedural development
Signature requirements:
Certificates of origin and specific permits, licenses, certificates, and authorisations
Electronic declaration forms:
Written, oral, and electronic declarations permitted
Language availability of referenced sources:
German, French, Italian
Year:
2015
Region / City:
United States
Theme:
Privacy, Data Systems, Homeland Security
Document Type:
Federal Register Notice
Agency / Institution:
Department of Homeland Security, U.S. Customs and Border Protection
Author:
Privacy Office, Department of Homeland Security
Target Audience:
General Public, Trade Community, Stakeholders in Homeland Security and Customs
Effective Date:
September 16, 2015
Approval Date:
Not specified
Date of Changes:
Not specified
Year:
2025
Region / city:
Australia
Subject:
Customs, Trusted Trader Programme
Document Type:
Regulation
Authority:
Australian Government, Comptroller-General of Customs
Author:
Gavan Reynolds AO
Target Audience:
Entities involved in international trade
Validity Period:
Ongoing from 2025
Approval Date:
21 August 2025
Amendment Date:
Not specified
Year:
2015
Region / city:
United States
Topic:
Privacy Act, Homeland Security, Customs and Border Protection
Document Type:
Federal Register Notice
Agency:
Department of Homeland Security, Privacy Office
Author:
Department of Homeland Security
Target Audience:
Public, stakeholders in the trade and customs sectors
Effective Date:
September 16, 2015
Approval Date:
August 17, 2015
Amendment Date:
Not specified
Year:
2020
Region / City:
United Kingdom, Republic of Korea
Subject:
Free Trade Agreement, Origin Reference Document
Document Type:
Regulation, Legal Text
Organization / Institution:
Government of the United Kingdom
Author:
UK Government
Target Audience:
Trade professionals, customs authorities, import/export businesses
Effective Period:
From 31st December 2025
Approval Date:
31st October 2025
Modification Date:
N/A
Contextual Description:
A regulatory document outlining the origin conditions for goods under the Free Trade Agreement between the United Kingdom and the Republic of Korea.