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In brief
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IN BRIEF
Views on recent developments in tax.
Practitioner view: Hybrid and other mismatch rules – double deduction issues
Matthew Mortimer
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Matthew Mortimer (Mayer Brown).
Practitioner view: The corporate interest expense restriction – risk allocation implications
Kitty Swanson
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Kitty Swanson (Mayer Brown).
Practitioner view: The rules recharacterising interest as a distribution – practical issues
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Catherine Richardson (Cadwalader, Wickersham & Taft).
Practitioner view: Unallowable purposes – ascertaining purpose
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Adam Blakemore (Cadwalader, Wickersham & Taft).
Transactions in securities: HMRC delays could cost it £34m
Chris Etherington
A freedom of information request highlights the extent to which HMRC has been enforcing the transactions in securities rules. The findings suggest an inconsistent approach by HMRC, with the average time for action to be taken potentially exceeding the permitted limits and over £34m of tax revenues at stake.
Allowances for UK pensions schemes
Four tax considerations.
The Budget measure on childcare support
The proposed extension of free childcare is great news, but is the eligibility criteria fair?
Spring Budget 2023: diminished expectations
Duncan Weldon
Jeremy Hunt hit a milestone this week by delivering his first Budget. Once upon a time, a chancellor delivering the annual Budget would be entirely unremarkable, but given his two predecessors did not last long enough in office to do so, the event...
Spring Budget 2023: some thoughtful tinkering
Jemma Dick
The Budget was a little on the boring side, but perhaps that is only because all the main policies had already been trailed? Not that anybody should be complaining nobody becomes a tax adviser because they are of the view that if you're not...
Spring Budget 2023: because it's all about the base, about the base...
Mike Lane
Two years' ago, I wrote a piece entitled 'The corporation tax rate rise', the gist of which was that by putting the headline rate of corporation tax up from 19% to 25% without narrowing the tax base the chancellor was predicting an increase in...
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
FA 2025 review: The loans to participators regime no more (re)paying your way
FA 2025 review: VAT on private school fees: a lack of clarity