HMRC consult on possible changes to the tax rules to accommodate contingent convertibles and other new forms of loss-absorbent instruments. Impact of proposed accounting changes on tax position has yet to be properly assessed.
Capital allowances anti-avoidance legislation is to be ‘improved’ and users of high-risk tax avoidance schemes will face tougher sanctions.
Audley re-affirms that highly prescriptive legislation is susceptible to purposive construction. In Parissis the First-tier Tribunal gives a wide interpretation to ‘power’ in the context of determining what documents are within a taxpayer’s ‘possession or power’.
