The Court of Appeal in BlackRock decides in favour of the taxpayer on transfer pricing, but HMRC wins on unallowable purpose. In Hargreaves Property, the Court of Appeal decides the interest on short but recurring loans is yearly interest and subject to withholding tax but takes a broader view of beneficial entitlement than the Upper Tribunal. HMRC updates its stamp taxes on shares guidance on the meaning of capital-raising arrangements and its capital gains guidance on share exchange clearances. The OECD publishes its promised consolidated version of the commentary on the GloBE model rules incorporating the three sets of administrative guidance released by the end of 2023.
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The Court of Appeal in BlackRock decides in favour of the taxpayer on transfer pricing, but HMRC wins on unallowable purpose. In Hargreaves Property, the Court of Appeal decides the interest on short but recurring loans is yearly interest and subject to withholding tax but takes a broader view of beneficial entitlement than the Upper Tribunal. HMRC updates its stamp taxes on shares guidance on the meaning of capital-raising arrangements and its capital gains guidance on share exchange clearances. The OECD publishes its promised consolidated version of the commentary on the GloBE model rules incorporating the three sets of administrative guidance released by the end of 2023.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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