HMRC's draft guidance on debt-buy backs by connected companies is reviewed by Richard Carson
The revised corporation tax rules on debt buybacks — by companies connected with the debtor — have been the subject of a number of articles over recent months. These new rules have been enacted in FA 2010 Sch 15. The provisions have changed little from the draft clauses published last November but there does remain some degree of 'hangover' from the initial confusion created by the original Ministerial Statement of 14 October 2009 and the subsequent attempt at clarification (see the HMRC statement of 22 October). We now have the benefit of draft HMRC guidance issued in April 2010; but whilst this is helpful in some respects it does not resolve all of the uncertainty in this area.
Amendments to CTA 2009 Part 5
Prior to the introduction of the new...
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HMRC's draft guidance on debt-buy backs by connected companies is reviewed by Richard Carson
The revised corporation tax rules on debt buybacks — by companies connected with the debtor — have been the subject of a number of articles over recent months. These new rules have been enacted in FA 2010 Sch 15. The provisions have changed little from the draft clauses published last November but there does remain some degree of 'hangover' from the initial confusion created by the original Ministerial Statement of 14 October 2009 and the subsequent attempt at clarification (see the HMRC statement of 22 October). We now have the benefit of draft HMRC guidance issued in April 2010; but whilst this is helpful in some respects it does not resolve all of the uncertainty in this area.
Amendments to CTA 2009 Part 5
Prior to the introduction of the new...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
