FUND-MANAGEMENT

Lee Squires and Fiona Bantock (Hogan Lovells) examine two recent cases, as well as recent HMRC briefings and the MOSS.

Commentary prepared by the Tolley tax team on the draft Finance Bill 2015 rules on:

• special purpose share schemes, with comment from Ashley Greenbank (Macfarlanes);
• diverted profits tax, with comment from Sandy Bhogal (Mayer Brown);
• investment managers and disguised fee income, with comment from Ben Eaton (Goodwin Procter);
• bank loss relief, with comment from Anna Anthony (EY).

William Watson recaps developments over the past year regarding the ability to recover VAT on services supplied in connection with the management of defined benefit pension schemes, in light of the PPG case.

Lee Squires and Fiona Bantock report on recent developments, including HMRC’s position on Littlewoods and pension fund management costs, the decisions in both Birmingham Hippodrome and Mercedes-Benz, and the advocate general’s opinion in K Oy, as well as forthcoming judgments to look out for.

Tony Beare considers the impact on the City. Plus, below, in-house Budget views from Jennie Rimmer and Paul Morton.