Jim Harra’s responses to specific questions asked by the Treasury Select
Committee about the Loan Charge are, at least in part, a masterpiece in
Yes Minister-style obfuscation, writes David Pett (Temple Tax Chambers).
Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.
The Advocate General’s opinion on the CFC Finco exemption state aid case, new US regulations and an update on Pillar Two are among the developments in this month’s review by Tim Sarson (KPMG).
Melville Rodrigues (Apex Group) and Naomi Lawton (Allen & Overy) provide an overview of the new regime that offers additional flexibility and plugs a gap in the UK’s existing fund range.
In light of reports that the Culture Secretary is lobbying for a reform of Gift Aid, Bill Dodwell (former OTS Tax Director) considers how the operation of that relief could be improved.
Recent decisions on mixed use SDLT, taxpayer behaviour and the meaning of ‘service’ under the remittance basis rules are reviewed by Edward Reed and Sam Epstein (Macfarlanes).
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