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Tax and the City review for September 2024

Speed read
The Supreme Court in Centrica Overseas Holdings determines that the capital test for an investment company is the same as for a trading company and accordingly the relevant deal fees were found to be capital and not deductible. The Upper Tribunal in UBS concludes that although HMRC had misdirected itself on the law the remedy was an order for HMRC to make a new decision rather than to compel HMRC to use its discretion to relieve UBS of the obligation to account for PAYE in respect of an ex-employee’s tax liability on earnings in the form of gilts. There is no money in the coffers to reduce the tax burden of financial services in the Autumn Budget but the business tax roadmap which will set out the government’s policy for business taxation for the years ahead should at least provide some certainty about how financial services will...

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