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  • The Commissioners for HMRC v The Prudential Assurance Company Limited Upper Tribunal (Tax and Chancery Chamber) [2023] UKUT 54 (TCC) Matching text sample:

    THE PRUDENTIAL ASSURANCE COMPANY LIMITED

    ...investment management services to The Prudential Assurance Company Ltd (“Prudential” or the “Appellant”)... ...were rendered while SCL and Prudential were both members of the... ...member of that VAT group. Prudential considered that those payments were...

    Prudential appealed against HMRC’s decision...

    At the relevant time, Prudential was a regulated life assurance company, the business of which...
  • Prudential Assurance Company Ltd v Commissioners for Her Majesty’s Revenue and Customs United Kingdom Supreme Court [2018] UKSC 39 Matching text sample:

    Prudential Assurance Company Ltd

    ...(“HMRC”) by the Prudential Assurance Co Ltd (“PAC”)...

    ...received by one UK-resident company, the source of which... ...made by another UK-resident company, were exempt from tax... ...levied once, on the latter company which made the profit out... ...the dividend to the former company.

    ...received by a UK-resident company, the source of which... was an overseas company, were in principle subject... ...But where the UK-resident company controlled a certain percentage of... ...power of the relevant overseas company (typically 10%), certain...
  • R (on the application of Prudential plc and another) v Special Commissioner of Income Tax and another United Kingdom Supreme Court [2013] UKSC 1 Matching text sample:

    (on the application of Prudential plc and another) (

    ...with its tax affairs, a company is entitled to refuse to...

    ...At about that time the Prudential group of companies instructed PwC... ...for their benefit. Thereafter the Prudential group implemented the scheme,...

    ...a substantial tax deduction in Prudential (Gibraltar) Ltd, a... subsidiary company of Prudential plc, which could then... ...against the profits of that company, which profits were ordinarily...
  • The Commissioners for HMRC v Applicants in the Post Prudential Closure Notice Applications Group Litigation & Anor Upper Tribunal (Tax and Chancery Chamber) [2024] UKUT 23 (TCC) Matching text sample:

    APPLICANTS IN THE POST PRUDENTIAL CLOSURE NOTICE

    TAXPAYERS IN THE POST PRUDENTIAL CLOSURE NOTICE

    ...investment funds and an insurance company (“the Taxpayers” or...

    ...less than 10% of a company’s share capital. A...
  • Rettig Heating Group UK Ltd, R (on the application of) v The Commissioners for HMRC Upper Tribunal (Tax and Chancery Chamber) [2024] UKUT 315 (TCC) Matching text sample:

    ...it had to another group company amending its own return accordingly... ...previously surrendered to its group company, and instead use the...

    ...limits for reasons beyond the company’s control. This would...

    ...of the time limit, the company or its agents were unaware... ...of profits against which the company could claim relief

    ...substantially the fault of the company or its agents

  • Sevilleja v Marex Financial Ltd United Kingdom Supreme Court [2020] UKSC 31 Matching text sample:

    ...in which A is a company, B is a creditor... of that company, and B’s loss...

    ...at the instance of a company rather than a natural person...

    Prudential Assurance Co Ltd v Newman Industries...

    The rule in Prudential, as I shall refer... ...is excluded even if the company does not pursue its own... ...the basis of the reasoning inPrudential, since its rationale is... ...an existence distinct from the company’s loss. On that... ...barred by the principle of company law known as the rule... ...an injury done to a company, where the company has a cause of action... , is the company itself.
  • Test Claimants in the Franked Investment Income Group Litigation v Commissioners for Her Majesty’s Revenue and Customs United Kingdom Supreme Court [2021] UKSC 31 Matching text sample:

    Prudential Assurance Co Ltd v Revenue and...

    ...FCE”), a UK registered company which was and is part... ...owned by the Ford Motor Company of Michigan, United States...

    Prudential Assurance Co Ltd v Revenue and...

    (“Prudential”). In that case...Prudential was a case in the... and Prudential, and the consequences of...
  • Intelligent Money Limited v The Commissioners for HMRC Upper Tribunal (Tax and Chancery Chamber) [2023] UKUT 236 (TCC) Matching text sample:

    ...establish a policy of life assurance, they may also purchase...

    ...used to purchase a life assurance contract (as one of...

    ...(provided by an independent insurance company) and income from the...

    Prudential Insurance Co v. Inland...
  • Berrisford (FC) v Mexfield Housing Co-operative Limited United Kingdom Supreme Court [2011] UKSC 52 Matching text sample:

    Prudential Assurance Co Ltd v London Residuary...

    ...[1989] Ch 1. In Prudential [1992] 2 AC 386...

    In Prudential [1992] 2 AC 386...

    ...the House of Lords in Prudential [1992] 2 AC 386...
  • Test Claimants in the Franked Investment Income Group Litigation and others v Commissioners for Her Majesty’s Revenue and Customs United Kingdom Supreme Court [2020] UKSC 47 Matching text sample:

    Prudential Assurance Co Ltd v Revenue and...

    (“Prudential”).

    ...Committee of Independent Experts on Company Taxation (the Ruding Committee)...

    ...this court’s decision in Prudential

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