LOAN-RELATIONSHIPS

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider HMRC’s updated unallowable purpose guidance, an advocate general opinion on state aid challenges to tax rulings and an Upper Tribunal case which raises some interesting points on distributions and procedural fairness.

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

Oliver Marre (5 Stone Buildings) examines a First-tier Tribunal decision that is important for anyone considering inter-group loan structuring.

Shinelock fails to extract pounds of tax relief from HMRC. David Whiscombe (BKL) reviews a case on loan relationships with some intriguing procedural issues.

Jenny Doak and Stuart Pibworth (Weil, Gotshal & Manges) revisit some of the key UK corporation and withholding tax considerations to consider on guarantees of financial obligations.

Robert Langston (Saffery Champness) considers new HMRC guidance that provides some clarification, although there are still areas that are left open. 

Heather Self (Blick Rothenberg) examines the Court of Appeal judgment in Ladbroke and its wider implications.

 

Mike Lane and Zoe Andrews (Slaughter and May) review recent developments affecting the City.

 

Heather Self (Pinsent Masons) examines the FTT decision where a UK corporate taxpayer succeeded in an argument about loan relationships or financial instruments against HMRC.