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Tax and the City review for September 2021

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The Court of Appeal in Target Group decides that the financial services exemption from VAT does not apply to the loan administration services Target supplied to a bank. The L-day materials published on 20 July of interest to financial institutions include large business notification of uncertain tax treatment (draft guidance for which has also been published), taxation of asset holding companies, amendment to hybrid mismatches rules and a consultation on the change to income tax basis periods. The FTT in Kwik-Fit applies the loan relationships unallowable purpose rule to disallow debits on certain loan relationships forming part of a reorganisation which was intended to accelerate the use of tax assets.
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