
Isadora Janssen is an associate in Sullivan & Cromwell’s London office advising on general U.K. corporate tax matters.
Associate, Sullivan & Cromwell LLP
Isadora Janssen is an associate in Sullivan & Cromwell’s London office advising on general U.K. corporate tax matters.
Royaume-Uni - Capital allowances - Enterprise zone allowances - The Supreme Court has held that a taxpayer was not entitled to enhanced capital allowances because variations to the contract under which the expenditure was incurred were sufficiently significant that the expenditure could not be treated as incurred under a contract made within the relevant time limits.
R (on the application of Cobalt Data Centre 2 LLP and another) v Commissioners for HMRC [2024] UKSC 40, 20 November 2024
Royaume-Uni - VAT grouping - The First-tier Tribunal considered three questions on HMRC's refusal to allow the UK branch of a foreign company to join a UK VAT group. HMRC's grounds were, first, that the company did not have a fixed establishment in the UK; and, second, that HMRC could deny the application in order to protect the revenu.
Barclays Service Corp and another company v Revenue and Customs Commissioners [2024] UKFTT 00785 (TC), 29 August 2024
Royaume-Uni - EU law - The Court of Appeal has held that a limitation on the surrender of losses within a group that applied only to permanent establishments of non-UK-resident companies is compatible with the EU principle of freedom of establishment.
VolkerRail Plant Ltd and others v HMRC [2023] EWCA Civ 210, 1 March 2023