Helen Lethaby reviews recent developments affecting the City, including draft Finance Bill provisions and recent decisions in Boyle, Eclipse and Versteegh
Total return swaps
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HMRC reached for the proverbial sledgehammer with the proposed new s 695A of CTA 2009. This provides for a tax disregard of debits and credits arising on derivatives which operate to shift all or part of the profits of a business from one group company to another effective from 5 December 2013. The measure is targeted at total return swaps under which all or a significant proportion of the profits of a UK company along with the risk of loss are transferred to an offshore company where they escape tax. (It is presumably the shifting of risk as well as profit which...
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