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Summer Finance Bill: The debt and derivative rules

A lot is changing in the debt and derivative rules although not as much as was originally proposed in HMRC’s 2013 consultation document. 
There are 43 pages of legislation in Sch 7 of the Finance Bill 2015. Accordingly this commentary merely seeks to summarise what the authors perceive as being the most fundamental changes to Parts 5 and 7 of CTA 2009 (‘the CTA 2009 provisions’); inevitably that is at the cost of some over-simplification. 
Our commentary is in three parts. The first part which deals with the fundamental principles and the second part which deals with the new regime-wide anti-avoidance rules – what might be called a mini-GAAR...

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