The final Spring Budget largely leaves the business tax regime unchanged, but the announcement that s 161 elections can no longer be made to convert capital losses into trading losses will be a disappointment for some. In the courts, HMRC has raised arguments, with differing results, as to whether accounts are GAAP-compliant and if the amounts brought into account ‘fairly represent’ the profits in GDF and Smith and Nephew. The taxpayers lose in TDS and Ladbroke, as all the loan relationship debits are disallowed under the unallowable purpose rule.
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