Karen Hughes corporate tax partner Lovells discusses the practical implications of the new loan relationships and derivative contracts 'degrouping' charges
The thing about the scattergun approach is that innocents may suffer. So it is with the Finance (No 2) Act 2005. A number of the anti-avoidance measures introduced by this Act were designed to counter schemes which had become apparent to HMRC through the tax disclosure rules. However the drafting of many of these measures is wide enough to catch more than tax avoidance schemes. The new 'degrouping' charges introduced in the context of the loan relationship and derivative contract rules are examples of this. This article outlines the new charges highlights particular points to note and considers the practical implications of the charges.
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Karen Hughes corporate tax partner Lovells discusses the practical implications of the new loan relationships and derivative contracts 'degrouping' charges
The thing about the scattergun approach is that innocents may suffer. So it is with the Finance (No 2) Act 2005. A number of the anti-avoidance measures introduced by this Act were designed to counter schemes which had become apparent to HMRC through the tax disclosure rules. However the drafting of many of these measures is wide enough to catch more than tax avoidance schemes. The new 'degrouping' charges introduced in the context of the loan relationship and derivative contract rules are examples of this. This article outlines the new charges highlights particular points to note and considers the practical implications of the charges.
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:
