The targeted anti-avoidance provisions that contain motive tests are being applied in ways which prevent the tax system from operating effectively, writes Constantine Christofi (RPC).
Companies emerging from the pandemic may undertake a debt restructuring. Paul Pritchard (FTI Consulting) discusses current tax issues with debt releases.
Chris Holmes (BDO) and David Hicks (Charles Russell Speechlys) consider the tax consequences of releasing wholly or partly recoverable inter-company debts.
Mandipa Soni and Edward Brown (Grant Thornton) discuss the taxation of loan relationships and derivatives for UK corporates, with a focus on convertible securities from the borrower’s perspective.
Ben Moseley, Helen Chadwick and Mo Malhotra (Deloitte) examine the key tax points in relation to the actions corporate treasurers are considering in response to economic impact of the Covid-19 pandemic.