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Tax and the City review for April 2023

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In Muller, the FTT considers the construction of the statutory fiction in CTA 2009 s 1259 and concludes that corporate members of an LLP are related parties of the LLP for the purposes of the intangibles regime. Measures in the Spring Finance Bill affecting financial services include improvements to enhance the attractiveness of the UK for investment, amendments to the tax treatment of reinsurance of BLAGAB and changes to the tax treatment of write-downs orders where insurers are in difficulty. The Upper Tribunal concludes in the Prudential case that the time of supply rules must be applied before the VAT grouping rules with the effect that the supplies were made for VAT purposes after the supplier left the VAT group and so were subject to VAT.

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