Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent
developments affecting the City.
Revised draft guidance on hybrids and other mismatches
HMRC published the (eagerly awaited?) updated draft guidance on hybrids and other mismatches on 31 March.
The changes are relatively modest which many could see as disappointing given the extensive consultation exercise (which encompassed both written representations and meetings with interested bodies).
Amongst the substantive changes is the addition of new guidance on the meaning of ‘reasonable to suppose’. The emphasis here (unsurprisingly) is that this will depend on the facts and circumstances but that it is in the first instance for the taxpayer to determine what it is reasonable to suppose. HMRC has put down a marker that this looks for a ‘rational justifiable and credible view of the likely outcome’ – and this may involve obtaining information from other...
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:
Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent
developments affecting the City.
Revised draft guidance on hybrids and other mismatches
HMRC published the (eagerly awaited?) updated draft guidance on hybrids and other mismatches on 31 March.
The changes are relatively modest which many could see as disappointing given the extensive consultation exercise (which encompassed both written representations and meetings with interested bodies).
Amongst the substantive changes is the addition of new guidance on the meaning of ‘reasonable to suppose’. The emphasis here (unsurprisingly) is that this will depend on the facts and circumstances but that it is in the first instance for the taxpayer to determine what it is reasonable to suppose. HMRC has put down a marker that this looks for a ‘rational justifiable and credible view of the likely outcome’ – and this may involve obtaining information from other...
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:
