HMRC beat a hasty retreat on treaty anti-avoidance but it remains to be seen whether the OECD will back off from the ‘beneficial ownership’ debate, explains Helen Lethaby in this month's briefing
HMRC recently issued a Brief on the application of the trading tests in the Substantial Shareholding Exemption. Lydia Challen and Andrew Howard consider the issues being addressed and the technical merits of the Brief.
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.