Ben Moseley and Stephen Weston look at draft Finance Bill 2011 provisions on group mismatch schemes
In launching the foreign exchange and financial instruments rules in 1993/4 and subsequently the loan relationship rules in 1996 and the derivative contract rules in 2002 the UK moved from a simple tax regime based on first principles to a detailed prescriptive regime for taxing and deducting amounts associated with debt and financial instruments. The new approach was needed to take account of the significant market developments in finance but inevitably any prescriptive regime attracts those keen to take advantage of the approaches set out. One of the themes of corporate taxation has been the use of those detailed rules to achieve tax advantages for commercial transactions. The government has sought to counter examples of planning which it disliked by writing even more detailed rules. More recently it’s become...
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Ben Moseley and Stephen Weston look at draft Finance Bill 2011 provisions on group mismatch schemes
In launching the foreign exchange and financial instruments rules in 1993/4 and subsequently the loan relationship rules in 1996 and the derivative contract rules in 2002 the UK moved from a simple tax regime based on first principles to a detailed prescriptive regime for taxing and deducting amounts associated with debt and financial instruments. The new approach was needed to take account of the significant market developments in finance but inevitably any prescriptive regime attracts those keen to take advantage of the approaches set out. One of the themes of corporate taxation has been the use of those detailed rules to achieve tax advantages for commercial transactions. The government has sought to counter examples of planning which it disliked by writing even more detailed rules. More recently it’s become...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
