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This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) examines the Court of Appeal decisions in BlackRock and Hargreaves Property, HMRC’s updated guidance on capital-raising arrangements and share exchange clearances, and the OECD’s consolidated commentary on the GloBE model rules.
Court of Appeal rules that ‘hire cap’ under the oil contractor regime applied to restrict CT deduction. 
Welcome but with some caveats. Alison Hughes and Lorna Jordan (KPMG) review HMRC’s new guidance on this issue.
Double tax treaty did not confer UK taxing rights to oil royalty payments.

Tax Journal's May 2013 exam supplememnt, with details of the latest successful candidates in the CTA and ATT examinations.

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