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.
While the UK’s new digital services tax hogged the limelight in the recent Budget, much less attention was paid to the fact that the proposed extension of withholding tax on royalties paid to tax havens (announced at the previous Budget) was...
The decision in Lloyds Bank Leasing illustrates an inherent problem with TAARs which employ purpose-based tests to restrict the availability of tax expenditure reliefs: since the point of tax reliefs is to alter taxpayer behaviour, why then should taxpayers be denied relief for responding accordingly?
William Watson (Slaughter and May) considers whether the forthcoming regime TAAR for loan relationships will be less problematic than what currently exists.
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