Market leading insight for tax experts
View online issue

Tax and the City review for May 2022

Speed read
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 are not a subscriber, subscribe now to read this content.
If you are already a subscriber, sign in
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.