It is in the tribunals and courts that many of the more interesting developments have taken place during 2023, writes Gerald Montagu (Gide).
Deductibility … of interest and other amounts
After maintaining a stiff-lipped silence since 2002 with respect to its guidance on the ‘unallowable purpose’ rule and somewhat unusually before aftershocks from court decisions have had a chance to settle HMRC published new (and considerably expanded) guidance on 9 March 2023. With appeals in BlackRock [2022] UKUT 199 (TCC) KwikFit [2022] UKUT 314 (TCC) and JTIC [2023] UKUT 194 (TCC) heading towards the Court of Appeal (in respectively March April and October 2024) the decision to update the guidance in May 2023 might be thought to be a little premature. However further evidence of HMRC’s focus on the unallowable purpose rule (and as in BlackRock transfer pricing) was...
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It is in the tribunals and courts that many of the more interesting developments have taken place during 2023, writes Gerald Montagu (Gide).
Deductibility … of interest and other amounts
After maintaining a stiff-lipped silence since 2002 with respect to its guidance on the ‘unallowable purpose’ rule and somewhat unusually before aftershocks from court decisions have had a chance to settle HMRC published new (and considerably expanded) guidance on 9 March 2023. With appeals in BlackRock [2022] UKUT 199 (TCC) KwikFit [2022] UKUT 314 (TCC) and JTIC [2023] UKUT 194 (TCC) heading towards the Court of Appeal (in respectively March April and October 2024) the decision to update the guidance in May 2023 might be thought to be a little premature. However further evidence of HMRC’s focus on the unallowable purpose rule (and as in BlackRock transfer pricing) was...
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