Hey, a new tax. As a tax adviser, that sounds like pretty good news. (Shame it is so bad for the country, but that's politics for you).
Secondary liabilities can present a significant concealed tax risk for a purchaser when acquiring a UK corporate target. Due to the wide reach of the provisions, a diligence review of target entities alone will often not identify all the potential tax risks. Mark Boyle and Joe Grehan (EY) provide this practice guide on steps to take to mitigate these risks
HMRC is taking an increasingly aggressive approach to disputes involving CTA 2009 s 441 – the targeted anti-avoidance rule on unallowable purpose. Those with genuine commercial borrowing, however, should stand firm, argues Heather Self (Pinsent Masons)
Emma Hardwick considers the point during sale negotiations at which a target may lose the ability to surrender or receive group relief
Vimal Tilakapala and Anne Powell examine the recent decision in UK v Council of the European Union, in which the CJEU decided that the UK’s legal claim in relation to the EU financial transaction tax was admissible, but premature.
Helen Lethaby reviews recent developments affecting the City.
The CJEU has dismissed as ‘premature and speculative’ the UK government’s challenge to the EU Council decision authorising 11 member states to establish enhanced cooperation towards the introduction of a financial transaction tax. In its decision, the court ruled that it cannot contest elements o
UK’s action against financial transaction tax fails
