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IPT
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BEPS
CFCs
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Issue 1613
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Issue 1613
Issue 1613
31 March, 2023
Analysis
Restrictions on tax deductibility of loan interest
EIS, VCTs and the Windsor Framework
The Windsor Framework and tax: same building, but a major renovation
Reflections on the state of tax today
Penalty appeals: shedding light on abuse of process
Preparing for corporation tax in the UAE: an in-house perspective
International review for March 2023
In brief
Practitioner view: Hybrid and other mismatch rules – double deduction issues
Practitioner view: The corporate interest expense restriction – risk allocation implications
Practitioner view: The rules recharacterising interest as a distribution – practical issues
Practitioner view: Unallowable purposes – ascertaining purpose
Transactions in securities: HMRC delays could cost it £34m
Allowances for UK pensions schemes
News
HMRC manual changes: 31 March 2023
Finance (No 2) Bill 2023 published
Lineker scores on IR35 appeal
UK MDR comes into force
Economic crime levy regs
Tax exemptions for designated bodies
HMRC updates guidance for charitable tax reliefs
Vietnam signs Mutual Assistance Convention
OECD publishes report on tax treaty abuse
HMRC interest rates increased again
Agent Update: issue 106
HMRC Stakeholder Digest
Cases
Mouldsdale t/a Mouldsdale Properties v HMRC
HFFX LLP and others v HMRC
Prisma Recruitment Ltd v HMRC
J Faiers v HMRC
Other cases that caught our eye 31 March 2023
One minute with
One minute with... Emmet Bulman
Trackers
HMRC manual changes: 31 March 2023
EDITOR'S PICK
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
1 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
2 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
3 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
4 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
5 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
6 /7
2024: that was the year that was
Jemma Dick
7 /7
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
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
NEWS
Read all
HMRC manual changes: 21 February 2025
HMRC launch e-invoicing consultation
NICs relief in special tax sites: postcode requirement introduced
Company size thresholds apply for off-payroll working rules
Paying voluntary NICs when abroad
CASES
Read all
A Taxpayer v HMRC
HMRC v Royal Bank of Canada
R (oao) Anglia Ruskin Students’ Union v HMRC
B Joseph v HMRC
Lloyds Asset Leasing Ltd v HMRC
IN BRIEF
Read all
Salaried members update
Themes in UK corporate tax disputes for 2025 (and beyond)
JVs and the top-up taxes: does HMRC’s draft guidance bring clarity?
Reflections on the Budget fallout – three months on
BlueCrest: the CA ruling on Condition B
MOST READ
Read all
Salaried members: HMRC reverses position on the TAAR and Condition C
Lloyds Asset Leasing Ltd v HMRC
Salaried members update
Mersey Docks: you’re my wonderwall
US ‘rejects very nature’ of UN tax talks