Detailed proposals for reform of the UK’s controlled foreign companies regime received a broad welcome from tax professionals but some experts warned that the new rules may not be compatible with European law.
Tax professionals have given a qualified welcome to detailed proposals for reform of the UK’s controlled foreign companies regime.
Bank loans to corporate borrowers are often supported by guarantees from related companies. Lydia Challen and Tim Harrop identify the principal tax issues on the provision of such a guarantee, from its creation to its termination
Cathryn Vanderspar and Charles Goddard examine how arguably outdated tax rules impact on the new financial landscape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