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CORPORATION TAX


HMRC has published draft guidance on changes to the treatment of carried-forward corporation tax losses from 1 April 2017. This is described as an initial tranche of guidance, focusing on the core rules and other aspects where guidance has been specifically requested.

Claire Hooper (EY) outlines the government’s plans to re-introduce measures dropped from the pre-election Finance Bill and looks at the changes made to the previous draft.
 
Adam Kefford and Stuart Rogers (PKF Francis Clark) answer a query on the status of international sales people working from home for the purposes of corporation tax in those jurisdictions.
 
The government is exploring taxing certain non-resident companies under corporation tax. Philip Spencer and Robin Hutton (BDO) consider the possible implications.
 
Emma Game and Dominic Robertson (Slaughter and May) consider the principal tax issues that can arise when establishing, operating and unwinding a corporate joint venture.
 

A survey of senior in-house tax experts, by Tax Journal in association with FTI Consulting, assesses the initial impact of the OECD’s recommendations on tackling base erosion and profit shifting.

The UK is pushing ahead with an interest barrier, following BEPS Action 4. Helen Lethaby and Helen Gunson (Freshfields Bruckhaus Deringer) examine the new UK rules which include some nasty tweaks to the OECD recommendations.
 
From 1 April 2017, there will be a substantial change to how corporation tax losses can be carried forward. Ben Jones and Dean Andrews (Eversheds Sutherland) examine the detail.
 
Karen Cooper (Cooper Cavendish) reviews the proposed changes to disguised remuneration and recaps the recent changes to date.
 

Tax insurance for M&A deals has been around for a while, but is now becoming broader in scope, and much more common. David Wilson (Davis Polk) provides an overview.

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