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Customs & Excise Commissioners v. Plantiflor Ltd., [2002] UKHL 33, [2002] 1 WLR 2287, [2002] STC 1132', [2002] BTC 5413 (HL)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply The taxpayer, which sold horticultural products by mail order, indicated in its catalogue that customers would pay an additional charge to cover the costs of postage and packing, and stated "we will then advance all postage charges to Royal Mail on your behalf. ...

Customs & Excise Commissioners v. Plantiflor Ltd., [2002] UKHL 33, [2002] 1 WLR 2287, [2002] STC 1132', [2002] BTC 5413 (HL)-- summary under Subsection 165(1) Summary Under Tax Topics- Excise Tax Act- Section 165- Subsection 165(1) The taxpayer, which sold horticultural products by mail order, indicated in its catalogue that customers would pay an additional charge to cover the costs of postage and packing, and stated "We will then advance all postage charges to Royal Mail on your behalf. ...

The Trustees of the Morrison 2002 Maintenance Trust & Ors v Revenue and Customs, [2019] EWCA Civ 93-- summary under Tax Avoidance Summary Under Tax Topics- General Concepts- Tax Avoidance Three “Scottish Trusts” exercised their put to sell shares of a listed public company to trusts (the “Irish Trusts”) with similar terms for the shares’ cost base of £4.5M; and the Irish Trusts sold the same shares eight days later to Merrill Lynch for £14.3M, who then sold the shares into the market. ... Newey LJ stated (at paras. 56-57) that he agreed with the First-tier Tribunal: that the sale to Merrill Lynch "sufficiently corresponded to the scheme as planned" and … it "would be extraordinary if the application of the Ramsay approach could be defeated by the sale being to brokers rather than to the market by brokers on behalf of the Irish Trustees" …. ...

The Trustees of the Morrison 2002 Maintenance Trust & Ors v Revenue and Customs, [2019] EWCA Civ 93-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) identifying the form of ultimate sale was not essential to finding a pre-ordained series A scheme for the avoidance by three trusts (the “Scottish Trusts”) of capital gains tax on the sale of a bloc representing approximately 2% of the shares of a listed company (”AWG”) turned on considering that the exercise by the Scottish Trusts of a put to sell the AWG shares for their base cost of £4.5M to trusts (the “Irish Trusts”) with similar terms did not occur (under the Ramsay approach) as part of a single composite transaction which included their sale eight days later to Merrill Lynch for their market value of £14.3M, who then sold the shares into the market. ... Dawson (quoted at para. 27): First, there must be a pre-ordained series of transactions; or, if one likes, one single composite transaction. …. ... The UT held that the FTT had been entitled to conclude that the involvement of Merrill Lynch made no material difference …. ...

S & C Ross Enterprises Ltd. v. The Queen, 2002 DTC 2078 (TCC)-- summary under Personal Services Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Personal Services Business The sole shareholder ("Ross") of the taxpayer served as the CFO of a Canadian company ("Clearly Canadian") and also performed services on behalf of the taxpayer for Clearly Canadian. ...

Customs & Excise Commissioners, [2002] BTC 5280 (Court in Session (Inner House))-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient The Appellant, which was entitled to issue its own bank notes, entered into a reciprocal agreement with other banks pursuant to which it was entitled to a flat fee per transaction when customers of the other banks were issued bank notes of the Appellant (or bank notes of the Bank of England) through ATMs of the Appellant. ...

Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) The son of the taxpayers (Mr and Mrs Pope), who was the beneficiary of a life insurance policy which he had purchased on his own life, was abducted in Angola by rebels in 1998. ... In 2002, the provider paid the £100,000 principal amount insured, plus an additional amount of £36,425.97. ... The payment had clearly been made as compensation for the deprivation between 1998 and 2002 of the principal amount. ...

Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)-- summary under Subsection 104(13) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13) The son of the taxpayer, who was the beneficiary of his own life insurance policy, likely died in 1998 when he was abducted by Angolan rebels, but this was never conclusively established. In 2002 the insurer paid the £100,000 principal amount insured to the taxpayer, plus an additional amount £36,425.97, which the Tribunal determined was interest. ...

Slipacoff, 2010 ONSC 2693-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission two-year limitations period The defendant and plaintiff held shares in an incorporated dental practice. ... Section 5 of Ontario's Limitations Act, 2002 essentially commences the limitations period from when the applicant knows or ought to know of a potential claim against the defendant. ...

On 3 April 2002 those two leases were extinguished by mutual surrender of the lessees, and the taxpayers therefore recovered full ownership of the properties. In May 2002 the taxpayers sold all the properties to third parties. Under section 4(9) of the VAT Act, no VAT was payable on those sales, as the properties had previously been the subject of a first supply on which VAT was chargeable, when the long lease was granted. ... …[T]he leases … had no commercial reality and were entered into … with the aim of reducing the VAT liability on the sales of immovable property … which they envisaged carrying out subsequently. ...