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IN BRIEF

Views on recent developments in tax.

The Court of Appeal confirms that the unallowable purpose rule in CTA 2009 s 441 denies interest deductions arising to the Kwik-Fit group from a group reorganisation designed to accelerate the use of tax losses and produce a tax saving for the group as a whole.
The Court of Appeal dismisses the taxpayers’ appeals.
The new IR35 ‘set-off’ mechanism came into effect from 6 April 2024. While this is good news, compliance with IR35 remains essential.
Managing to clarify management – or not.
Labour’s response makes it more complicated for clients to assess their options.
The Upper Tribunal disagrees with HMRC’s strict application of compliance obligations for the discharge of inward processing relief procedure.
A tough test, even for footballers

The Council is working to find an agreement on outstanding tax files, while attention shifts towards the new European Commission's tax agenda. 

Further detail on last week’s proposals, including Labour’s thinking on remitting FIGs.
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