Mike Lane warns of further potential uncertainty
The reform of the loan relationships and derivative contracts rules was announced in this year’s Budget following an internal review and on 6 June 2013 HMRC published a lengthy (109 page) consultation document Modernising the taxation of corporate debt and derivative contracts (‘the condoc’). Responses to the condoc are due by 29 August 2013 with a view to legislating in Finance Bill 2014 and Finance Bill 2015.
It is fortunate that I am not a cynic. Because a cynic reading this document might think this is merely HMRC seeking to rewrite the legislation in the manner in which with hindsight it would like it always to have been written and in which in many cases it is still...
