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IN BRIEF

Views on recent developments in tax.

HMRC updates its guidance in light of the Castlelaw FTT decision.
Some large businesses hit by covid-19 may never obtain effective tax relief on bone fide commercial borrowings.
HMRC’s revised proposal is an improvement on the original, but the link between lost tax revenue and the need for new notification rules remains a puzzle.
Two recent tribunal decisions reach different conclusions on the application of TMA 1970 s 30B.
No need for a commission.
A recent Upper Tribunal ruling further clarifies distinction between plant and premises for capital allowances purposes.
The UK law change from 1 June 2021 will lead to withholding tax costs on UK outbound interest and royalty payments.
Although the guidance provided by the Upper Tribunal in Atholl House is welcome, it serves to re-emphasise the degree of uncertainty created by the IR35 rules.
UK B2B businesses learn the true cost of Brexit.
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