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Tax and the City review for September 2019

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The UT overturns the FTT’s decision in Hargreaves Lansdown finding that the loyalty bonuses were ‘pure income profit’ of the investors and therefore annual payments. The latest cases on tax indemnities (Stobart Group and Zedra) serve as further warnings to purchasers to comply with the exact terms of the relevant contract: in Stobart Group the notice provision for the purpose of bringing a claim against the seller; in Zedra the overprovisions clause requiring the purchaser to provide the seller with a copy of the full auditors' report). Lawyers accountants financial institutions and other ‘intermediaries’ pore over the UK’s consultation on implementation of DAC 6 which requires the mandatory automatic exchange of information between tax authorities in relation to cross-border arrangements which meet one or more hallmarks. Draft legislation for Finance Bill 2019/20 is published and includes provision for payment by instalments following the...

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