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Tax and the City review for January 2020

Speed read
HMRC issued a statement on CFC state aid recovery which includes an explanation of how the OECD approach to significant people functions should be applied to intra-group lending. The decision of the Upper Tribunal in Target Group Ltd illustrates the difficulty for a third party providing outsourced functions to a bank to meet the strict requirements for VAT exemption. HMRC publishes revised consolidated guidance on the code of practice on taxation for banks, alongside the 2019 annual report on the operation of the code. The reform of the international tax rules continues to be a hot topic for 2020 as the OECD builds on the latest public consultation responses to facilitate a consensus solution by the end of 2020.

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