This month's review of tax developments affecting the City, by Mike Lane and Zoe Andrews (Slaughter and May).
CFC state aid recovery: HMRC’s statement
HMRC has applied to the EU General Court to annul the Commission’s decision that the UK’s CFC exemption for finance income which would otherwise be brought into charge as a result of it being derived from UK activity is state aid. Nevertheless the UK is still required to collect the state aid for the period 1 January 2013 to 31 December 2018 where finance income is derived from UK activity pending any subsequent annulment of the decision. (The rules were changed to remove the offending exemption from 1 January 2019.)
So how will HMRC recover the supposedly unlawful state aid? HMRC has sent a statement on recovery of state aid to affected companies. The statement confirms that...
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This month's review of tax developments affecting the City, by Mike Lane and Zoe Andrews (Slaughter and May).
CFC state aid recovery: HMRC’s statement
HMRC has applied to the EU General Court to annul the Commission’s decision that the UK’s CFC exemption for finance income which would otherwise be brought into charge as a result of it being derived from UK activity is state aid. Nevertheless the UK is still required to collect the state aid for the period 1 January 2013 to 31 December 2018 where finance income is derived from UK activity pending any subsequent annulment of the decision. (The rules were changed to remove the offending exemption from 1 January 2019.)
So how will HMRC recover the supposedly unlawful state aid? HMRC has sent a statement on recovery of state aid to affected companies. The statement confirms that...
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:
