Tax and the City briefing for November 2012

CRD4 compliance will not result in relief being denied for tier 2 capital. More tinkering is proposed to the worldwide debt cap rules. The Court of Appeal confirms that Boake Allen is not a panacea to all of HMRC’s non-discrimination article woes, holding in FCE Bank that the article allowed a group relief group to be traced through a US parent pre-2000. The Explainaway CGT planning fails to convince the Upper Tribunal. HMRC will not be represented on the GAAR advisory panel. A group of 10 Member States seek to go it alone on a financial transaction tax.