Mark Middleditch (Allen & Overy) reviews the latest tax developments that matter affecting the City.
David Boneham (Deloitte) summarises the changes arising from the government’s review of the loan relationships and derivative contracts rules.
Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual
HMRC’s position on the unallowable purpose rule seems as complex as ever. Mike Lane reviews where things currently stand