The Chartered Institute of Taxation has raised with HMRC several concerns regarding draft legislation designed to counter a tax avoidance scheme, disclosed by Barclays, which sought to avoid the charge on ‘deemed releases’ of loan relationships.
Sara-Jane Donovan and Jennifer Pearce examine the latest update from the government on the new controlled foreign companies regime. Is the gate now open for multinationals?
Chris Harrison and Ben Brown examine the key corporation tax deductibility and VAT recovery issues on M&A deals.
An updated ‘Gateway’ features in HM Treasury’s latest update on CFC reform, published yesterday.
James Wilson sets out a risk-based approach to the rules.
Mike Lane explains why the regime may be susceptible to challenge under EU law.
Martin Lambert and Zoe Wyatt provide a practical guide.
Michael Bird and Jonathan Bridges examine IP issues.
From Kevin Ashman, Tony Beare, Andrew Boucher, David Clissitt, Elizabeth Conway, Jonathan Cooklin, David Harkness, Robert Edwards, Aurell Taussig, Duncan Whitecross, James Wilson, Mark Edwards, Paul Morton and David Smith.
Paul Shaw and Kevin Cummings explain how to handle the tax rules on this topical issue.