Corporate residence of subsidiaries: Court of Appeal decision provides more questions than answers

In the recent case of HMRC v Development Securities, the Court of Appeal (CA) considered the tax residence of three Jersey-incorporated subsidiaries of a UK company. Overturning the decision of the Upper Tribunal (UT), the CA reinstated the decision of the First-Tier Tribunal (FTT) that the three subsidiaries were resident in England, resulting in the defeat of the company group’s tax planning arrangements.

Related briefings

‘Tax Day’ – government continues its campaign to tackle non-compliance

In the UK’s first ever ‘Tax Day’ on 23 March 2021, the government released more than 30 consultation documents relating to the future landscape of the UK tax regime. Whilst these documents scrutinised how taxes should be paid, opportunities for simplification and the potential of digitalisation, it was tackling non-compliance which was firmly in the spotlight once again. Tax & estate planning Partner, James Austen, gives his opinion on the proposed measures.

Latest Briefings

Irish regulation in focus: Culture and individual accountability

Increasingly, there is a focus on culture and individual accountability in regulated firms. This has been heightened by various consumer protection issues which have been investigated including the tracker mortgage examination; high profile enforcement actions and the recent engagement with insurers on business interruption cover during COVID-19. Consistently, the Central Bank of Ireland (“Central Bank”) […]



Gibson Dunn at the helm for Trustpilot IPO

Review platform Trustpilot is planning to list on the London Stock Exchange, as the IPO market starts to pick up in the City. Gibson Dunn & Crutcher is advising the company on aspects of English and US law. The firm’s team is being led by partners Chris Haynes and US-qualified Steve Thierbach. Morgan Stanley and […]

London skyline

Covington’s London revenue jumps by 12 per cent

Covington & Burling’s London revenue increased by 12 per cent last year, as global turnover also saw double-digit growth. This is after the firm’s City growth was static in 2019, decreasing by 0.1 per cent. In 2020, the firm’s revenue in its London offering leapt to $113.6m from $101.2m. In 2015, the firm’s London turnover […]

legal tech

Shoosmiths branches into consulting with new venture

Shoosmiths has launched a new separate consultancy arm, as firms ramp up efforts to provide alternative services for clients. ‘Shoosmiths8 Connected Services’ has been established to help clients with their legal, as well as broader business requirements. It includes a suite of eight products across innovation, contracts, coaching, corporate advisory, privacy and data. The eight […]

Bryan Cave Leighton Paisner, BCLP

BCLP releases final part of withheld profit distributions

Bryan Cave Leighton Paisner (BCLP) has joined the raft of firms to have repaid UK Government funds used as part of the furlough scheme. It has emerged that BCLP repaid the funds in the early part of January. The firm had put on the scheme an unspecified number of business services professionals when the pandemic […]

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