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Babies, Bathwater & Loan Relationships

Fiona Thomson and Roger Muray of Ernst & Young LLP cast a critical eye over the draft rewrite of the Loan Relationships provisions
The idea of rewriting the entire body of UK direct taxation legislation was proposed to Parliament back in December 1995. The main objective of the Tax Law Rewrite programme has been to simplify the presentation of tax legislation to make it clearer more certain and more accessible to businesses and ordinary taxpayers. But an important principle was that the fundamental meaning of the legislation should remain unchanged.
A significant amount of time and money has been invested in this process which has culminated in the enactment of several new Acts predominantly dealing with income tax. Whatever benefits the rewrite might have brought so far it...

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