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Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.
Gerald Montagu (Gide Loyrette Nouel) examines the recent decision in Barclays Bank Plc v HMRC.
Anne Powell (Bryan Cave Leighton Paisner) considers how our historic experience of tax covenants steer us to resolve new Pillar Two risks.
Tax Journal’s recent coverage of the Keighley case has largely focused on connected companies issues. Here, Mark Whitehouse and Mairead Cummins (PwC) focus on the other key issue in that case: the ‘gateway test’ for the deductibility of loan relationship debits.
Significant employment tax charges can arise in certain insolvency situations where there was never an intention for rewards to be provided in connection with employment, write Jon Preshaw and Ben Proctor (Jon Preshaw Tax).
The Court of Appeal’s decision in Dolphin Drilling and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Heather Self (Blick Rothenberg) considers the tax issues surrounding compensation payments made by the Post Office to subpostmasters.
Oliver Walker and Akash Mehta (Weil, Gotshal & Manges) consider the current status of the TCGA 1992 s 137 main purpose test.
The move to permanent full expensing marks a change in UK corporate tax strategy, writes Jasmine Kaur, Head of Capital Allowances at HM Treasury.
It is in the tribunals and courts that many of the more interesting developments have taken place during 2023, writes Gerald Montagu (Gide).