Cases

Inmarsat Global Ltd v Revenue and Customs Commissioners [2021]

Judgment Date: 23 Mar 21

Facts The taxpayer company appealed the First-tier Tribunal's refusal of its claim that it was entitled to capital allowances in respect of the costs of launching six satellites.The International Maritime Satellite Organisation (IMSO) had entered into a series of contracts for the construction of six satellites which were novated...

HMRC v Smith & Nephew (2020)

Judgment Date: 03 Mar 20

Summary Michael Gibbon QC (leading James Rivett QC of Pump Court Tax Chambers) has appeared for HMRC in an important test-case central aspects of the loan relationships code, in particular the “fairly represents” provision, and the proper treatment of exchange gains and losses. Facts Three companies in the Smith & Nephew...