COMPLIANCE

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?

Mike Lane

Zoe Andrews

Hybrid capital instruments technical noteFA 2019 repealed and replaced the regulatory capital securities regime from 1 January 2019 with a new hybrid capital instrument (HCI) regime.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

Thomas Dalby (Gabelle) reviews an Upper Tribunal decision on CT deductions for share options.

Michael Avient

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.

Ross Robertson

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...

David Porter

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...

Dan Neidle

Rob Sharpe

The European Commission concludes that part of UK’s CFC tax regime gave unlawful state aid to certain multinational companies. Dan Neidle and Rob Sharpe (Clifford Chance) report.

Bridget English

Richard Sultman

Bridget English and Richard Sultman (Cleary Gottlieb) discuss key tax issues arising from the anticipated discontinuation of LIBOR and transition to alternative ‘nearly risk free’ rates.

Dan Nazarian Donna Huggard Mark Groom Patricia Mock

This report, which sets out the key tax changes taking effect from April, was prepared by Deloitte’s Mark Groom (partner), Patricia Mock (tax director), Dan Nazarian (associate director) and Donna Huggard (associate director).

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