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Corporate taxes
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CORPORATE TAXES
Writing off a loan: the unallowable purpose trap
Mark Whitehouse
Mairead Cummins
Tax Journal
’s recent coverage of the
Keighley
case has largely focused on connected companies issues. Here, Mark Whitehouse and Mairead Cummins (PwC) focus on the other key issue in that case: the ‘gateway test’ for the deductibility of loan relationship debits.
Difficult choices: disguised remuneration in the context of corporate insolvency
Jon Preshaw
Ben Proctor
Significant employment tax charges can arise in certain insolvency situations
where there was never an intention for rewards to be provided in connection
with employment, write Jon Preshaw and Ben Proctor (Jon Preshaw Tax).
Tax and the City review for February 2024
Zoe Andrews
Mike Lane
The Court of Appeal’s decision in
Dolphin Drilling
and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Tax clouds on the Horizon for the Post Office?
Heather Self
Heather Self (Blick Rothenberg) considers the tax issues surrounding compensation payments made by the Post Office to subpostmasters.
On purpose: developments in the main purpose test
Oliver Walker
Akash Mehta
Oliver Walker and Akash Mehta (Weil, Gotshal & Manges) consider the
current status of the TCGA 1992 s 137 main purpose test.
The move to permanent full expensing
Jasmine Kaur
The move to permanent full expensing marks a change in UK corporate tax strategy, writes Jasmine Kaur, Head of Capital Allowances at HM Treasury.
2023: a parting glance in the rear view mirror for corporate tax practitioners
Gerald Montagu
It is in the tribunals and courts that many of the more interesting developments have taken place during 2023, writes Gerald Montagu (Gide).
New R&D scheme misses the point
Justine Dignam
The latest R&D reforms were said to simplify the tax regime and encourage
business investment. The reality though is more complexity, writes
Justine Dignam (Markel Tax).
The resurgence of crown preference: the dog in the manger
Eloise Walker
Are we seeing a slow return to Crown preference (including for corporation tax) by the back door, asks Eloise Walker (Pinsent Masons).
Unlawful distributions: why knowledge matters
Helen Coward
Lewis Currie
Helen Coward and Lewis Currie (Charles Russell Speechlys) consider the
consequences of unlawful distributions by UK companies, including the tax
pitfalls to avoid.
Go to page
of
300
EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
HMRC manual changes: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Autumn Budget 2024: IHT winners and losers
UK signs new double tax treaty with Romania