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Tax and the City review for January 2022

Speed read
HMRC consults on draft regulations to improve the tax regime for hedging risks on anticipated future share transactions. In the Hargreaves Property Holdings Ltd case, the FTT’s purposive interpretation of ‘beneficial entitlement’ in the context of the exclusion from withholding for payments to a UK resident company beneficially entitled to the interest has potentially far-reaching consequences. The 2021 annual report on the code of practice on taxation for banks shows that banks continue to show improved behaviour in the year to 31 March 2021. Further progress is made with international tax reform with the release of model rules for part of the pillar two global minimum tax rules.
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