The new arena
Historically, intra-group financial transactions were generally subject to less tax authority scrutiny than those relati...
Large Corporate
Large Corporate
Raiders of the loss relief
In the early days of my tax career, nearly 25 years ago, there was a legislative provision that I thought a very useful ...
International exchange
HMRC have changed the way companies must comply with FATCA, clarifying the obligations including those under the common ...
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Taking the credit
The research and development expenditure credit (RDEC) was introduced by the Finance Act 2013 and has led to a change in...
Raising taxes
Slowly the word crept out that there would be a great deal in the summer Budget – although details of the content remain...
Deductible relationships
A UK tax resident company has borrowed, so has a loan payable amount. Interest accrues on the loan.
The interest ratio
One action from the G20/OECD Base Erosion and Profit Shifting project – Interest Restrictions (action 4) – potentially a...
Loss relief limits
Seasoned observers of the European Court of Justice in Luxembourg point out that there was a high-water mark in deciding...
Caught in a diversion
The autumn statement announced a new diverted profits tax (DPT) applying at a rate of 25% from 1 April 2015....
Policing the boundary
For individuals, the distinction between corporate bonds that are qualifying corporate bonds (QCBs) and those that are n...