In another case involving both commercial and unallowable purposes the Court of Appeal in Kwik-Fit decides that some of the loan relationship debits can be allocated to the commercial purpose. In a blow to taxpayers the Court of Appeal in Hotel La Tour decides that input tax in respect of deal fees in relation to a share sale are attributable to the exempt share sale (and therefore irrecoverable) rather than to the taxpayer’s downstream taxable general economic activities. The FTT allows an application on behalf of the wider tax community for skeleton arguments to be made public in the Osmond and Allen case relating to the transactions in securities legislation. The Inclusive Framework announced its intention for the multilateral convention to implement Amount A of Pillar One to be open for signing by the end of June (the expiry of the interim period for the transitional approach...
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In another case involving both commercial and unallowable purposes the Court of Appeal in Kwik-Fit decides that some of the loan relationship debits can be allocated to the commercial purpose. In a blow to taxpayers the Court of Appeal in Hotel La Tour decides that input tax in respect of deal fees in relation to a share sale are attributable to the exempt share sale (and therefore irrecoverable) rather than to the taxpayer’s downstream taxable general economic activities. The FTT allows an application on behalf of the wider tax community for skeleton arguments to be made public in the Osmond and Allen case relating to the transactions in securities legislation. The Inclusive Framework announced its intention for the multilateral convention to implement Amount A of Pillar One to be open for signing by the end of June (the expiry of the interim period for the transitional approach...
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