GROUPS

Cathryn Vanderspar and Charles Goddard examine how arguably outdated tax rules impact on the new financial landscape

Michael McKenna and Kunal Vyas review the impact of Bayfine UK and the OECD discussion draft on the meaning of ‘beneficial ownership’ on the interpretation of double tax treaties

Elizabeth Bradley, Richard Harbot and Katherine Durkacz consider the issues for financial services groups relating to the new chargeable gains degrouping rules

Ian Sandles examines the impact of the new rules on the financial sector

The most common form of consensual corporate restructuring is the debt-for-equity swap. Marcus Rea examines the tax issues

HMRC have published an ‘informal consultation’ to explore potential changes to the debt cap rules in TIOPA 2010 Part 6 which restrict restricting tax relief for interest and other finance costs. Comments are invited by 5 September. ...

Robert Langston provides an outline of the rules in TCGA 1992 s 13 which can attribute the gains of overseas companies to UK shareholders