CFC reform looks set to be less radical than taxpayers might initially have hoped, according to the latest ConDoc. Consultations are also launched on changes to the regime for unauthorised unit trusts, the residence test for individuals, the rules for non-doms and the disclosure hallmarks. Draft bank levy double tax relief regulations have been published. BAA Ltd loses its case on the recoverability of VAT incurred on professional fees in the course of a takeover bid, and the Court of Appeal’s decision on the compatibility of the UK’s old thin cap rules with EU law is now the final word. HMRC have revised their Litigation Settlement Strategy.
