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The Ladbroke case and unallowable purpose

Heather Self (Pinsent Masons) considers a recent case about a complex financial transaction where HMRC prevailed on an ‘unallowable purpose’ argument. 
7 January 2016 /
Self's assessment: Amazon
In this new regular column Heather Self (Blick Rothenberg) provides an expert view on a tax issue which made the headlines in the national press. The first topic under review – how much tax should Amazon pay?
 
28 August 2018 /
What is an unallowable purpose?

HMRC is taking an increasingly aggressive approach to disputes involving CTA 2009 s 441 – the targeted anti-avoidance rule on unallowable purpose. Those with genuine commercial borrowing however should stand firm argues Heather Self (Pinsent Masons)
2 October 2014 /
Self's assessment: signs of a ceasefire in the digital trade war?
In our continuing series Heather Self reviews tax issues that make the headlines in the national press. This week the impact of the new US proposals on international tax reform.
15 April 2021 /
Raising the stakes on tax avoidance

Heather Self and Ray McCann examine HMRC’s proposals on high-risk tax promoters. Plus further reaction from Michael Avient and a Q&A on the proposals by Jonathan Levy.
29 August 2013 /
What should be done about carried interest?
Most would probably agree that the current rate of tax on carried interest is too low. But whatever solution is adopted a balance needs to be struck between complexity and ‘fairness’ writes Heather Self (Blick Rothenberg).
12 July 2023 /
Self's assessment: to boldly go where no chancellor has gone before?
In our continuing series Heather Self examines the tax issues that make the headlines in the national media. This week should the chancellor reform NICs?
3 March 2020 /
Self's assessment: Tax and the cost of living crisis
In our continuing series Heather Self examines the tax issues that make the headline news. This week why tax changes might not be the best way of delivering targeted support for the cost of living crisis.
24 May 2022 /
HMRC v Lomas and others: an interesting case
Heather Self (Blick Rothenberg) assesses the impact of the recent Court of Appeal judgment in Lomas on whether interest is ‘short’ or ‘yearly’.
 
22 February 2018 /
Self's assessment: The pensions triple lock
In our continuing series Heather Self examines the tax issues that make the national headlines. This week she examines whether it is time to break the pensions triple lock.
14 September 2023 /
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