Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.
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.
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).
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).