CTA

The Court of Appeal has clarified when remuneration and pension provision will satisfy the ‘wholly and exclusively’ test – and when a tax avoidance purpose will defeat a deduction, writes Aparna Nathan KC (Devereux Chambers).

Zoe Andrews

Mike Lane

The latest developments that matter, reported by Mike Lane and Zoe Andrews (Slaughter and May).

Constantine Christofi

Anna Lucey

HMRC’s nudge campaign signals a broader challenge to deductibility under CTA 2009 s 1219, write Anna Lucey and Constantine Christofi (EY).

Ross McGregor

Hannah Manning

In the first of two articles examining the close companies rules, Hannah Manning and Ross McGregor (Travers Smith) explain why it should not be assumed that a company is not close without looking carefully at the relevant legislation.

Hugh Gunson

With all the publicity that has surrounded other parts of FA 2025, practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81. The rules: The ‘loans to participators’ rules in...

Scope and operation of the ‘imported loss’ restriction in CTA 2009 s 327 for loan relationships

Ellen Wildig

Sarah Ling

Sarah Ling and Ellen Wildig (Macfarlanes) explore the wider impact for family-controlled businesses of the upcoming reforms to business property relief.

Supreme Court ruling on oil contractor regime

Zoe Andrews

Mike Lane

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) examines the Court of Appeal decisions in BlackRock and Hargreaves Property, HMRC’s updated guidance on capital-raising arrangements and share exchange clearances, and the OECD’s consolidated commentary on the GloBE model rules.

Court of Appeal rules that ‘hire cap’ under the oil contractor regime applied to restrict CT deduction.

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