International exchange
HMRC have changed the way companies must comply with FATCA, clarifying the obligations including those under the common ...
Large Corporate
Large Corporate
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...
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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...
Born in the USA
With the recent increase in international enforcement activities undertaken by the US Internal Revenue Service (IRS) and...
Wrong sort of dividend
Judge Colin Bishopp has just given his decision in a case about ‘rate boosters’.