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Tax and the City briefing for June 2018

Speed read

Carried-forward losses on succession of a trade must be streamed and may be set against only that part of the successor’s trade arising from the succeeded trade according to the Court of Appeal’s construction of ICTA 1988 s 343 in Leekes. Business looks beyond Brexit and continues to value the UK’s stable and competitive tax regime according to the latest tax competitiveness report. The Coal Staff Superannuation Scheme Trustees Ltd test case determines that the pre-2014 manufactured overseas dividends (MODs) regime was a restriction on free movement of capital, the remedy for which is repayment of the £8.8m income tax equal to the relevant withholding tax deducted from the gross amount of the MODs. The government confirms it intends to publish consolidated versions of double tax treaties that have been amended by the MLI ‘in good time’ before the modifications take effect.

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