HMRC has modified its proposals for strengthening the bank code of conduct, allowing banks greater rights of appeal before being named and shamed. New rules will prevent individuals from claiming corresponding adjustments under the transfer pricing rules, a move mis-trailed at the Lib Dem party conference as closing a private equity tax loophole. Working groups have been meeting to discuss reform of the loan relationship and derivative contract regimes, with the treatment of debt restructurings remaining a key area of concern. The financial transaction tax (FTT) would infringe the rights of non-participating states and distort competition, according to the EU Council’s lawyers.
