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Johnston Publishing (North) Ltd v HMRC

Anneli Collins and Paul Cooper, partners in KPMG´s M&A Tax group, look at the implications for M&A work of the Special Commissioners´ decision in Johnston Publishing

 
Anneli Collins and Paul Cooper partners in KPMG´s M&A Tax group look at the implications for M&A work of the Special Commissioners´ decision in Johnston Publishing
 
The decision in Johnston Publishing (North) Ltd v HMRC SpC 564 was released in October and although not widely publicised could have a significant impact on past and future deals if not overturned. The case looked at the interpretation of the associated company exemption in TCGA 1992 s 179(2) — an issue that has been a long-running debate between HMRC and many companies and their advisers. In round one HMRC has won but the decision is...

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