Heather Self (Pinsent Masons) examines the First-tier Tribunal case of Stagecoach, the latest case involving a complex intra-group financing scheme.
Unsuccessful loan relationship avoidance scheme
David Boneham (Deloitte) reviews a recent First-tier tribunal decision that uses FA 1996 s 84(1) – the ‘fairly represent’ loan relationship rule – as an anti-avoidance provision stopping accounting principles being used as a way of taking profits out of the tax net.
In this month’s briefing, Mark Middleditch (Allen & Overy) provides a round-up of recent tax developments affecting the City, including: the decisions in Sir Fraser Morrison (contingent CGT liability for shareholder-director) and Project Blue (SDLT anti-avoidance); new tax relief for corporate rescues; and the Office of Tax Simplification’s report on partnership taxation.
Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual
For any transaction involving bonds or notes, there are a number of potential difficulties that may arise, which may include issues involving stamp taxes, VAT, withholding tax, FATCA, and the tax treatment of the bond issuer and bondholders. Eloise Walker and Abigail McGregor provide a handy practice guide for advisers
Helen Lethaby reviews recent developments affecting the City.
Tony Beare looks at the Budget measures affecting multinational companies