Although much of our tax dispute and litigation work is confidential, some of the publicly reported cases in which Lovells has been involved are:
- Inland Revenue Commissioners v Trustees of Sema Group Pension Scheme - the application of the anti- avoidance provisions in Part XVII of the Income and Corporation Taxes Act 1988 to share buybacks
- Trinity Mirror plc v Customs and Excise Commissioners - the nature of an issue of shares for VAT purposes.
Purves (Inspector of Taxes) v Harrison - the availability of retirement relief on a sale of land nine months before the sale of the rest of the business.
- Manufacturers' Life Assurance Co Ltd v Cummins (Inspector of Taxes) - the computation of the taxpayer company’s chargeable profits for corporation tax purposes on the I minus E basis.
- Inland Revenue Commissioners v John Lewis Properties plc - the nature of monies received under rent factoring arrangements.
- Customs and Excise Commissioners v Barclays Bank plc - the date upon which a company ceases to be a member of a group for VAT purposes.
- Customs and Excise Commissioners v Mirror Group plc - the nature of reverse premiums paid by a landlord to a prospective tenant.
- Customs and Excise Commissioners v Kingfisher plc -the application of the VAT doctrine of 'abuse of rights' to the sale of face value vouchers.
- Barclays Bank plc v HM Revenue & Customs - the nature of debt negotiation services.
- Weight Watchers (UK) Ltd v HM Revenue & Customs - the appropriate test to be applied in determining when a single or multiple supply takes place for VAT purposes.
- HM Revenue & Customs v Loyalty Management UK Ltd - to whom a supply is made in retail promotions that involve multiple parties.