The obvious conclusion from the Upper Tribunal decision is that every standalone company should form a dormant subsidiary, writes Robert Langston (Saffery Champness), but there are anti-avoidance rules to consider.
Unsure how the ‘double reasonableness’ test works? Sukhbir Binning and Ian Robotham (Pinsent Masons) provide a refresher guide to this ground-breaking legislation.
Dominic Lawrance and Elinor Boote (Charles Russell Speechlys) discuss the uncertainty of the reporting requirements and the potentially serious regulatory burdens for tax professionals dealing with international matters.
Two recent decisions have demonstrated conflicting approaches to the interpretation of multi-step transactions, write Angela Savin and Harry Smith (KPMG).