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Many corporates now have a lower appetite for tax risk, and taxpayers are concerned about HMRC's increasingly interventionist approach.

The Court of Appeal has recently interpreted the MSC legislation more widely than expected, paving the way for HMRC to target arrangements previously thought to be low risk, as Kevin Barrow and Ian Hyde (Osborne Clarke) explain.
Tm Sarson (KPMG) reviews the latest developments that matter.

Three recent tax-related developments in the insolvency and restructuring sphere.

What is a just and reasonable apportionment of profits as an alternative to time apportionment?
Hybrid capital instruments technical noteFA 2019 repealed and replaced the regulatory capital securities regime from 1 January 2019 with a new hybrid capital instrument (HCI) regime. An HCI is a loan relationship under which the debtor (but not the...
Thomas Dalby (Gabelle) reviews an Upper Tribunal decision on CT deductions for share options.
What is and is not included in a self-assessment? Michael Avient examines the taxpayer victory at the Supreme Court on a carry back loss claim.
FA 2019 makes several changes and additions to the diverted profits tax (DPT) legislation within FA 2015 Part 3.The DPT impacts multinational businesses where transactions between the UK and foreign companies are perceived to lack economic substance...
Schedule 14 of this years Finance Act impacts lessees accounting under IFRS 16 for periods of account starting on or after 1 January 2019. IFRS 16 brings operating leased assets onto the balance sheet of the lessee for the first time, and the...
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