HMRC is right to assert that the ‘no possibilities’ test should be applied immediately after the base loss period for losses from 1 April 2006, but wrong to apply it to periods before that date, writes Peter Cussons (PwC).
Double tax treaty relief on dividends
75 in-house tax directors and heads of tax from large companies share their views on the coalition government's tax policies and priorities for a new government.
How will a lower corporation tax rate benefit the Northern Irish economy? Eamonn Donaghy, head of tax at KPMG Belfast, explains that Northern Ireland, due to its disproportionately small private sector and shared border, is well-suited to reap the full advantages of a lower corporation tax rate.
Chris Morgan (KPMG) comments on the new corporate tax year which commences on 1 April.
Martin Zetter (Macfarlanes) reviews the latest transfer pricing developments, including this month's OECD's public consultation on transfer pricing papers.
Chris Morgan (KPMG) provides a review of recent international tax developments that matter.
HMRC has made welcome changes to the new diverted profits tax, which takes effect from 1 April. As a result, the tax should not disrupt commercially based planning supported by economic substance, writes Shiv Mahalingham (Duff & Phelps).
Two changes particularly catch the eye, one welcome and one not so, writes Mike Lane (Slaughter and May).
Amendments to the consortium relief link company concept in the draft Finance Bill 2015 conclude a protracted period of change for this concept, driven by EU law. Ben Jones and Sarah Illidge (Eversheds) report.