In JTIAC, the latest decision on the loan relationships unallowable purpose rule, the FTT finds in favour of HMRC that none of the relevant debits are deductible even though the loan relationship funded the acquisition by a UK company of a target group from a third party. The FTT concludes in the Beard case that payments made by a Jersey company out of share premium are dividends of an income, not capital, nature. The Supreme Court finds in favour of HMRC in the Coal Staff Trustees case on whether the manufactured overseas dividends tax regime (as it existed pre-January 2014) involved any restriction on the free movement of capital and so contravened EU law.
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In JTIAC, the latest decision on the loan relationships unallowable purpose rule, the FTT finds in favour of HMRC that none of the relevant debits are deductible even though the loan relationship funded the acquisition by a UK company of a target group from a third party. The FTT concludes in the Beard case that payments made by a Jersey company out of share premium are dividends of an income, not capital, nature. The Supreme Court finds in favour of HMRC in the Coal Staff Trustees case on whether the manufactured overseas dividends tax regime (as it existed pre-January 2014) involved any restriction on the free movement of capital and so contravened EU law.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
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