Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Smith & Nephew: GAAP-compliant accounts and ‘fairly represents’
The first of two cases in this briefing to look at exchange losses arising as a result of a change in functional currency Smith & NephewOverseas Ltd and others v HMRC [2018] UKUT 393 (TCC) is an unusual example of a loss creation case being won by the taxpayer in the current climate. By way of contrast Ball UK Holdings discussed below involved a scheme which had been disclosed under DOTAS and the Upper Tribunal (UT) decided that case against the taxpayer.
Following a reorganisation the taxpayers changed their functional currency from sterling to US dollars. It was agreed that the taxpayers were obliged to change their functional currency the point at issue was how...
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:
Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Smith & Nephew: GAAP-compliant accounts and ‘fairly represents’
The first of two cases in this briefing to look at exchange losses arising as a result of a change in functional currency Smith & NephewOverseas Ltd and others v HMRC [2018] UKUT 393 (TCC) is an unusual example of a loss creation case being won by the taxpayer in the current climate. By way of contrast Ball UK Holdings discussed below involved a scheme which had been disclosed under DOTAS and the Upper Tribunal (UT) decided that case against the taxpayer.
Following a reorganisation the taxpayers changed their functional currency from sterling to US dollars. It was agreed that the taxpayers were obliged to change their functional currency the point at issue was how...
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:
