The First-tier Tribunal has finally given a decision on the loan relationships unallowable purpose test, 15 years after its introduction. Matthew Hodkin discusses whether it was worth the wait.
The new CTA 2010 s 27 (attribution to persons of rights and powers of their associates) inserted by FA 2011 is reflected in an updated Small Profits Rate and Marginal Relief Toolkit, HMRC announced.
An avoidance scheme in which the recipient of a manufactured overseas dividend (MOD) seeks a credit for UK income tax where ‘no actual UK income tax has been paid’ is to be blocked with effect from 15 September.
The Finance Act 2011, Section 43 (Appointed Day) Order, SI 2011/2280, appoints 15 September 2011 as the day on which FA 2011 s 43 comes into force.
Inter-company debt: whether a ‘loan relationship’
The UK and the US are acutely aware of the need for competitive effective tax rates but, as Steve Edge and Willard Taylor explain, they achieve that result in different ways.
With the SAO certification deadline looming for many companies, Ed Dwan explains how best to qualify or caveat the certificate where a particular area falls short of the requirements.