Table Of Content

Index Accounting Standards, Charities, development of, 473 et seq. consideration given by, covenanted payments for, 496 et seg. finance lease, for, 474 et seq. covenanted payments to, 496 et seq. influence of, tax cases in, 476 et seq. Citizen’s Charter, 301 et seq. leasing transaction, for, 474 et seq. Commercial Accounting, Accounting, Trading Profits, for, trading profits, to determine, clear guidance by courts, whether, 468 et seq. clear guidance by courts, whether, 468 et seq. Advance Corporation Tax, Companies, Budget proposals, reduction of surplus, for, 330 et seq., 332 controlled foreign. See Controlled Foreign Companies. et seq. European, 114 et seq. proposals for reform, 289 et seq. group relief. See Group Relief. Agent, mergers, 105 et seq. And see Mergers. permanent establishment, whether, parent/subsidiary, 105 et seq. OECD Model, under, 341 et seq. resident and non-resident. See Resident and Non-Resident Appeal by Case Stated, Companies. restrictions, 238 et seq. taxation of profits and dividends, Appeals, international review, 90 et seq. book, 522 Company Cars, Approved Share Option Schemes, Finance Bill, 266 et seq. Finance Bill, 278 et seq. Complaints Procedure, Assessment, Revenue Adjudicator, appointment of, (and see Revenue simpler system for, Adjudicator), 301 et seq. consultative document, 65 et seq. Continental Shelf, Benefits in Kind, double taxation agreements, 189 et seq. average cost basis, 187 et seq. Controlled Foreign Companies, Finance Bill, 271 et seq. Finance Bill, 281 et seq. marginal cost basis, 185 et seq. Corporate Taxation, market value basis, 188 et seq. European Community, 75 et seq. school fees, 172 et seq. Deep Discount Securities, Books, Finance Bill, 264 et seq. 1993 VAT system, 180 et seq. Deep Gain Securities, double taxation agreement, 182 Finance Bill, 265 et seq. interest, deductibility of, 520 et seq. Demerger, international tax law, 182 classification of income and capital of shares issued in, 406 partnership taxation, 524 et seq. et seq. tax appeals, 522 et seq. Discrimination, Business Expansion Scheme, non-resident companies and resident companies between, 435 loan linked investments, et seq. Finance Bill, 279 et seq. Dividends, Capital Allowances, foreign. See Foreign Dividends. Finance Bill, 280 imputation system, Capital Gains Tax, review, 90 et seq. principal private residence, 12 et seq., 24 et seq. Domicile, Law of, settled property, Law Commission’s proposals, 46 et seq. extra statutory concession, 70 et seq. reform, 42 et seq. Capital Losses, Double Taxation Agreements, Finance Bill, 273 et seq. book, 182 Capital Transfer Tax, continental shelf, 189 et seq. scheme to avoid, Eastern Caribbean, 395 et seq. distribution to elderly beneficiary, where, 414 et seq. non-discrimination article, 435 et seq. Car Tax, OECD Model. See OECD Model Tax Convention. abolition, permanent establishment, agents as, 341 et seq. Finance Bill, 256 U.S./Netherlands, Caribbean, limitation of benefits, 97 et seq. double taxation agreements, 395 et seq. Double Taxation Relief, Case Stated Procedure, dividends, restrictions, 238 et seq. international review, 90 et seq. INDEX Double Taxation Relief—cont. Finance Bill—cont. United Kingdomy/Ireland, interest payments, multinational groups, in, 256 et seq. inheritance taxes, 384 et seq. NSDDS, 272 et seq. Dwelling-house, oil taxation, 282 et seq. definition, 12 et seq., 17 et seq. penalties, Eastern Caribbean, VAT, 255 double taxation agreements, 395 et seq. residence, 285 et seq. Editorial Plan, British Tax Review, for, 5 triangular transactions, Enforcement, VAT, 252 foreign revenue claims, of, 313 et seq. Financial Instruments, Eurobonds, interest rate/currency risk management, for, paying and collecting agent rules, 325 proposals, 429 et seq. European Community, Foreign Dividends, 1993 VAT System, paying and collecting agent rules, 319 et seg. books, 180 et seq. Foreign Exchange Gains and Losses, corporate taxation, 75 et seq. Finance Bill, 276 et seq. Economic Interest Grouping, 134 et seq. Foreign Tax Credit Relief, European Company proposals, 114 et seq. analysis of, 201 et seq. harmonisation, credit limit, 212 et seq. corporate taxation, 75 et seq. creditable tax defined, 200 et seq. group relief, review of, 517 et seq. income arising, meaning of, 204 et seq. indirect taxes, 164 et seq. Fuel for Domestic Use, indirect taxes, VAT, 252 excise duties, 170 et seq. Fuel for Vehicles, VAT history, 166 et seq. VAT, 252 mergers directive, 105 et seq. General Commissioners, parent-subsidiary directive, 105 et seq., 426 adversarial jurisdiction, whether, 52 et seq. Ruding Committee Report, 75 et seq. inquisitorial role, whether, 52 et seq. triangulation, 160 et seq. role assessment, 52 et seq. European Company, Gold, proposals for, 114 et seq. scheme for, European Economic Interest Grouping, 134 et VAT, 253 seq. Group Relief, 249 et seq. Family Investment Company, European Community harmonisation, 517 et seq. unitisation of portfolio, 247 share ownership, Filkin, Elizabeth, arrangements affecting, 249 et seq. appointment of, 301 et seq. option arrangements, 249 et seq. Finance Act 1993, Hansard, drafting, review of, 483 et seq. use of, oil taxation, 434 et seq. statutory interpretation for, 1 et seq. review, 483 et seq. Hardman, Philip, Finance Bill, obituary, 73 et seq. approved share option schemes, 278 et seq. H.R.H. Queen Elizabeth II, bad debt relief, taxation of, 71 et seq. VAT, 254 Historical Perspective, Taxation of, benefits in kind, 271 et seq. 1932-1945, 230 et seq. business expansion scheme, 279 et seq. Imputation Systems, capital allowances, 280 company dividends, for, capital losses, 273 et seq. international comparisons, 90 et seq. car tax, abolition of, 256 Income Tax, company cars, 266 et seq. assessment. See Assessment. controlled foreign companies, 281 et seq. benefits. See Benefits. deemed supplies, Indirect Taxes, VAT, 254 European Community, 164 et seq. foreign exchange gains and losses, 276 et seq. Inheritance Tax, fuel for domestic/charity use, U.K./Ireland, VAT, 252 double taxation relief, 384 et seq. fuel for vehicles, Inland Revenue, VAT, 252 complaints procedure, 301 gold, new scheme for, Input Tax, VAT, 253 appeals, input tax appeals, 253 Finance Bill, 253 Interest Payments, Parent-Subsidiary Measures, deductibility, E.C. directive, 105 et seq. book, 520 et seq. Partnership Taxation, multi national groups, in, 256 et seg. book, 524 et seq. charge under accrued income scheme, 259 et seq. Penalties, deep discount securities, 264 et seq. VAT, deep gain securities, 265 et seq. Finance Bill, 253 exempted debts, 258 et seq. Petroleum Revenue Tax, qualifying debts, 257 et seq. Finance Bill, 282 et seq. International Tax Law, Principal Private Residence, 12 et seq., 24 et seq. book, 182 dwelling-house, identification of, 12 et seq., 17 et seq. Ireland/United Kingdom, Reasonable Excuse, inheritance taxes, late payment of VAT, for, double taxation relief, 384 et seq. insufficiency of funds, 175 et seq. Journalists, Rent Free Periods, cost of newspapers for, tenant’s work in return for, 6 et seq., 10, 11 deductible expenditure, whether, 410 et seq. VAT, 6e t seq. Judicial Review, Residence, development in tax field, 219 et seq. available accommodation rule, abolition of, Lease, Finance Bill, 285 et seq. grant with rent-free period, Resident and Non-Resident Companies, VAT, 480 et seq. discrimination between, whether, 435 et seq. surrender for consideration, Restitution, Law of, VAT, 479 et seq. recovery of overpaid taxes, and, 442 et seq. Life and Taxes, Returns, 1932-1945, 230 et seq. electronically submitted, proposal for, 401 et seq. 1945-1965, 294 et seq. Revenue Adjudicator, 301 et seq. 1965-1992, 504 et seq. appointment, 301 Life Assurance, independence, 302 et seq. disposal of interests in unit trusts, 307 et seq. ombudsman, distinguished from, 304 distributions, UK companies, from, 311 role, 301 et seq. management expenses, 311 et seq. Ruding Committee Report, 75 et seq. overseas companies trading in UK, 308 et seq. dividends, taxation of, double taxation relief, 93 et seq. Finance Act, 306 et seq. Schedule E, transfer of assets between business classes, 310 et seq. deductible expenditure, transfer of long term business, 306 et seq. newspapers for journalists, cost of, 409 et seq. Mergers, principle re-stated, 410 et seq. E.C. directive, 105 et seq. School Fees, Monarchy, The, benefit, as, 172 et seq. taxation of, 71 et seq. sed victa Catoni Netherlands, translation, 304 et seq. treaty with U.S.A., Settled Property, limitation of benefits, 97 et seq. interest in possession, Newspapers, capital gains tax, 70 et seq. journalists, for, Share Ownership, deductible expenditure, whether, 410 et seq. arrangements affecting, NSDDS, variation to rights, whether, 249 et seq. Finance Bill, 272 et seq. option arrangements, 249 et seq. Non-Discrimination, Share Valuation, non-resident companies and resident companies between, 435 information standards, 240 et seq. et seq. private companies, Norway, court’s discretion, disagreement, where, 240 double taxation agreements, Seq. continental shelf, 189 et seq. information not in public domain, 241 et seq. OECD Model Tax Convention, no information, valuation date at, 245 et seq. permanent establishment, agents as, 341 et seq. Shares, Oil Taxation, classification of income and capital of, Finance Act, 434 et seq. indirect demergers, issued in, 406 et seq. Finance Bill, 282 et seq. Single Market, Overpaid Taxes triangular transactions, law of restitution and, 442 et seq. VAT, 252 INDEX Statutory Interpretation, United States of America, Hansard, use of for, 1 et seq. treaty with Netherlands, Switzerland, limitation of benefits, 97 et seq. double taxation agreement, Value Added Tax, continental shelf, 189 et seq. 1993 European System, Tax Appeals, books, 180 et seq. book, 522 et seq. bad debt relief, Taxation, Finance Bill, 254 historical context, in car tax, abolition of, 1932-1945, 230 et seq. Finance Bill, 256 Taxpayer’s Charter, 301 et seq. deemed supplies, complaints procedure, 301 et seq. Finance Bill, 254 Tax Returns. See Returns. fuel for domestic/charity use, Tenancy, Finance Bill, 252 rent-free periods, fuel for vehicles, VAT, 6 et seq. Finance Bill, 252 Trading Profits, gold, scheme for, accounting for, Finance Bill, 253 court guidance on, 468 et seq. input tax appeals, Transnational Enforcement of Tax Liabilities, 313 et Finance Bill, 253 seq. leasing transactions, 479 et seq. Triangulation, penalties, VAT, 160 et seq. Finance Bill, 255 Unilateral Relief, 201 et seg. And see Foreign Tax Credit reasonable excuse for late payment, Relief. insufficiency of funds, 175 et seq. United Kingdom/Ireland, rent-free periods, 6 et seq. inheritance taxes, triangulation, 160 et seq. double taxation relief, 384 et seq. Finance Bill, 252 a ks Fas Beas Soke ae