The FTT in Blackrock finds in favour of the taxpayer on transfer pricing and on the application of the unallowable purpose test. The Court of Appeal in Total decides that for the accounting period which straddled the tax rate increase the taxpayers were entitled to elect to apportion profits on an actual basis rather than by way of time apportionment with the result that profits escaped the 32% rate of supplementary charge. Whilst the EU proposes a modernisation of VAT on financial and insurance services we wait to see what changes the UK might make after the end of the Brexit transition period. Regulations are enacted providing for the circumstances in which loss absorbing instruments (such as shares and convertible debt) issued by overseas subsidiaries of UK resident entities can be deducted from equities and liabilities otherwise chargeable to the bank levy. According to the OECD’s...
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The FTT in Blackrock finds in favour of the taxpayer on transfer pricing and on the application of the unallowable purpose test. The Court of Appeal in Total decides that for the accounting period which straddled the tax rate increase the taxpayers were entitled to elect to apportion profits on an actual basis rather than by way of time apportionment with the result that profits escaped the 32% rate of supplementary charge. Whilst the EU proposes a modernisation of VAT on financial and insurance services we wait to see what changes the UK might make after the end of the Brexit transition period. Regulations are enacted providing for the circumstances in which loss absorbing instruments (such as shares and convertible debt) issued by overseas subsidiaries of UK resident entities can be deducted from equities and liabilities otherwise chargeable to the bank levy. According to the OECD’s...
If you are not a subscriber, subscribe now to read this content.
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