Issue 1613

Analysis

• Restrictions on tax deductibility of loan interest
• EIS, VCTs and the Windsor Framework
• The Windsor Framework and tax: same building, but a major renovation
• Reflections on the state of tax today
• Penalty appeals: shedding light on abuse of process
• Preparing for corporation tax in the UAE: an in-house perspective
• International review for March 2023

In brief

• Practitioner view: Hybrid and other mismatch rules – double deduction issues
• Practitioner view: The corporate interest expense restriction – risk allocation implications
• Practitioner view: The rules recharacterising interest as a distribution – practical issues
• Practitioner view: Unallowable purposes – ascertaining purpose
• Transactions in securities: HMRC delays could cost it £34m
• Allowances for UK pensions schemes

News

• HMRC manual changes: 31 March 2023
• Finance (No 2) Bill 2023 published
• Lineker scores on IR35 appeal
• UK MDR comes into force
• Economic crime levy regs
• Tax exemptions for designated bodies
• HMRC updates guidance for charitable tax reliefs
• Vietnam signs Mutual Assistance Convention
• OECD publishes report on tax treaty abuse
• HMRC interest rates increased again
• Agent Update: issue 106
• HMRC Stakeholder Digest

Cases

• Mouldsdale t/a Mouldsdale Properties v HMRC
• HFFX LLP and others v HMRC
• Prisma Recruitment Ltd v HMRC
• J Faiers v HMRC
• Other cases that caught our eye 31 March 2023

One minute with

• One minute with... Emmet Bulman

Trackers

• HMRC manual changes: 31 March 2023