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6 documents found
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Saranac Partners Limited v The Financial Conduct Authority
Upper Tribunal (Tax and Chancery Chamber)
[2024] UKUT 254 (TCC)
Matching text sample:
...overlap with references made by Barclays –– Decision Notice based...
...had previously been employed by Barclays Bank plc, a subsidiary... of Barclays plc
...we have not distinguished between Barclays plc and Barclays Bank plc unless it is... ...have instead used the abbreviation “Barclays”.
...capital raising exercise conducted by Barclays in June 2008 and the... ...to a report produced for Barclays by a consultancy called Genesis... ...2012 but only disclosed to Barclays’ regulators in December 2012....
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The Commissioners for HMRC v Marlborough DP Limited
Upper Tribunal (Tax and Chancery Chamber)
[2024] UKUT 98 (TCC)
Matching text sample:
...that MDPL would obtain a corporation tax deduction for the payments...
...treatment, for both income and corporation tax purposes, of the...
...discovery assessments in respect of corporation tax came before the First... ...computing its profits chargeable to corporation tax (which we shall...
...scheme attempted to achieve a corporation tax deduction for MDPL in...
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The Commissioners for HMRC v Blackrock Holdco 5, LLC
Upper Tribunal (Tax and Chancery Chamber)
[2022] UKUT 199 (TCC)
Matching text sample:
business of Barclays Global Investors (“BGI US... ”) from Barclays Bank plc in December 2009
...the UK and registered for corporation tax.
Income and Corporation Taxes Act 1988
Corporation Tax Act 2009
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William Reeves v The Commissioners for HMRC
Upper Tribunal (Tax and Chancery Chamber)
[2018] UKUT 293 (TCC)
Matching text sample:
...XI of the Income and Corporation Taxes Act 1988 dealing with...
Barclays Mercantile Business Finance Ltd v...
, Barclays, claimed a capital allowance... ...the proceeds of sale which Barclays paid for the pipeline.... ...incurred for the purpose of Barclays’ finance leasing trade because... ...to the purchase price after Barclays had paid it. But... ...reality of the expenditure by Barclays.
...to small companies’ relief from corporation tax, such relief being...
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The Tower One St George Wharf Limited v The Commissioners for HMRC
Upper Tribunal (Tax and Chancery Chamber)
[2024] UKUT 373 (TCC)
Matching text sample:
...plan”) showing that a corporation tax (“CT”) advantage...
...by PwC of the possible corporation tax advantage that could be...
...received the advice about the corporation tax advantage that could be...
...effective to produce the expected corporation tax advantages, the group... ...region of £44 million in corporation tax (being the tax...
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THE COMMISSIONERS FOR HER MAJESTY’S REVENUE AND CUSTOMS v BLUECREST CAPITAL MANAGEMENT LP & Ors
Upper Tribunal (Tax and Chancery Chamber)
[2022] UKUT 200 (TCC)
Matching text sample:
...Partner at the (lower) corporation tax rates. It was...
Income and Corporation Taxes Act 1988
...computed for the purposes of corporation tax in like manner,...
...partners during that period, and corporation tax shall be chargeable as...
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