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Tax and the City review for May 2019

Speed read
HMRC publishes a revised hybrid capital instruments technical note, which includes new commentary on takeover and change of control clauses. The EU Commission publishes its full decision on the UK’s CFC finance company exemption. The FTT decision in Oxford Instruments serves as a useful reminder of the limitation of tax rulings and that not all motive tests work in the same way. HMRC responds to stakeholders’ concerns about the profit diversion compliance facility.

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