The development of corporate taxation in Britain and Ireland followed in most respects an identical path between 1853 and 1922. By 1925, however, the Irish Free State and the United Kingdom had become radically different in approach, with Ireland taking the more recognisably modern path. This...

This Chapter reviews the law and administration of capital allowances, from the introduction of a general plant and machinery allowance in 1878 to the first few years of operation of the prototype modern system of the Income Tax Act 1945. It is discovered that the period, far from representing...

In this chapter we examine the Board of Referees, an innovative administrative body established in 1915 with the remit of resolving certain questions relating to the assessment of the wartime Excess Profits Duty. The Board is particularly notable for its composition of eminent members of the...

An obscure case of 1909 reveals a wider story around the nature and origin of the “renewals” basis of capital allowance and raises doubts as to the removal of this basis by HMRC in 2013. A proper analysis of the case also brings in various questions of statutory interpretation and...

This article examines the history of relief for tax losses in the UK, with an emphasis on excess capital allowances, excess management expenses and the indefinite carry-forward of trading losses. It is argued that the early development of this area of law was characterised by repeated...

The merger of HM Commissioners of Inland Revenue and HM Customs and Excise in 2005 stands out as one of the most instantly recognisable reforms of the UK Civil Service in recent times. A good deal has been written about the consequences of the merger, but we focus in this chapter on the period...

This chapter examines the relevance of public law scholarship to taxation, with a particular focus on the resolution of disputes relating to constitutional and administrative law, the contribution of tax law to the creation and survival of states, and the relevance of political values to tax...