The FTT in Keighley agrees with HMRC on its interpretation of ‘control’ in the loan relationships connected parties’ rule but on the facts determines the parties were not connected although the deduction for the debit on the write-off of a loan was still denied albeit by the unallowable purpose rule. The Spring Budget confirms that a new type of investment fund the Reserved Investor Fund will be legislated for in the Spring Finance Bill with details of the new regime to be provided in secondary legislation. The taxpayers in Clipperton lose their appeal for the third time with the Court of Appeal concluding the tribunals had correctly applied the Ramsay approach to conclude the taxpayers had received a distribution in respect of their shares upon which tax was due. HMRC publish a call for evidence on powers penalties and safeguards with some...
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The FTT in Keighley agrees with HMRC on its interpretation of ‘control’ in the loan relationships connected parties’ rule but on the facts determines the parties were not connected although the deduction for the debit on the write-off of a loan was still denied albeit by the unallowable purpose rule. The Spring Budget confirms that a new type of investment fund the Reserved Investor Fund will be legislated for in the Spring Finance Bill with details of the new regime to be provided in secondary legislation. The taxpayers in Clipperton lose their appeal for the third time with the Court of Appeal concluding the tribunals had correctly applied the Ramsay approach to conclude the taxpayers had received a distribution in respect of their shares upon which tax was due. HMRC publish a call for evidence on powers penalties and safeguards with some...
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