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Profits arose from oil extraction activities
Scope and operation of the ‘imported loss’ restriction in CTA 2009 s 327 for loan relationships
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
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. 
Welcome but with some caveats. Alison Hughes and Lorna Jordan (KPMG) review HMRC’s new guidance on this issue.
Double tax treaty did not confer UK taxing rights to oil royalty payments.

Tax Journal's May 2013 exam supplememnt, with details of the latest successful candidates in the CTA and ATT examinations.

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