Issue 1597

Analysis

• Wholly and exclusively: does a tax motive prevent deductibility?
• QAHCs and UK securitisation companies: awkward bedfellows?
• Share deals: when is the optimum time to sell?
• Private client review for November 2022
• Two wins for HMRC in DCM Optical Holdings narrow the scope of VAT challenges

In brief

• The CJEU’s ruling in the Fiat state aid case
• Employee group life cover: protection from unexpected tax charges
• The energy windfall tax hokey cokey

News

• HMRC manual changes: 18 November 2022
• R&D tax credits claims fall in value
• The CIOT’s three tax priorities
• Loan charge discovery assessments
• Value of UK business tax reliefs reaches £105bn
• Adoption of IFRS 17 by insurance companies
• Gibraltar: continued access to financial services markets
• Money laundering: updated list of high-risk countries
• Pillar One rules should be ‘proportionate to the intended policy objectives’, says CIOT
• Agreement on exchange of information
• HMRC revises ADR guidance
• Paper repayment notifications to end in December

Cases

• Other cases that caught our eye: 18 November 2022
• NTK Leisure Ltd v HMRC
• T Watts v HMRC
• Fiat Chrysler Finance Europe and others v European Commission

One minute with

• One minute with... Russell Warren

Trackers

• HMRC manual changes: 18 November 2022