Group financing arrangments: tackling hybrid mismatches
One of the key targets of the G20 led Base Erosion and Profit Shifting project was multinational groups that e...
Large Corporate
Large Corporate
Loss carry back rules: the case of Civic Environmental Systems
When writing this article, I was reminded of my article ‘What a carry back’ in the January 2020 issue of Tax A...
Rescuing a business from insolvency: gaining more time to pay your debts
There are several routes to rescue an insolvent company, but to give a business the best possible chance of re...
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Customs duties and transfer pricing: can we bring these more in line?
Following updates to HMRC customs valuation guidance issued in late 2022, the interaction between transfer pri...
The future for whistleblowing: speak up and stop harm
Rarely a day goes by without a whistleblowing story in the press – from patient safety concerns in hospitals, ...
UK imports and exports: the impact of Brexit
HMRC estimated that the number of businesses importing or exporting would rise from 250,000 prior to Brexit to...
Beneficial loans: the importance of getting your timing right
I can remember the first time that I came across an assessment in relation to a loan to a participator. ...
Combining employee ownership trusts with share schemes: a complicated compound
More and more is being written about employee ownership trusts and the tax incentives available when establish...
Changes in the UK tax system: the power of statistics
One of the spin-off benefits of the Budget is that it gives us the opportunity to have a broader look at the U...