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IN BRIEF

Views on recent developments in tax.

Another HMRC victory on ‘grounds’.
The Court of Appeal confirms that the unallowable purpose rule in CTA 2009 s 441 denies interest deductions arising to the Kwik-Fit group from a group reorganisation designed to accelerate the use of tax losses and produce a tax saving for the group as a whole.
The Court of Appeal dismisses the taxpayers’ appeals.
The new IR35 ‘set-off’ mechanism came into effect from 6 April 2024. While this is good news, compliance with IR35 remains essential.
Managing to clarify management – or not.
Labour’s response makes it more complicated for clients to assess their options.
The Upper Tribunal disagrees with HMRC’s strict application of compliance obligations for the discharge of inward processing relief procedure.
A tough test, even for footballers

The Council is working to find an agreement on outstanding tax files, while attention shifts towards the new European Commission's tax agenda. 

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