Detailed proposals for reform of the controlled foreign companies regime do not reflect the government’s ‘high level aims’, according to the Chartered Institute of Taxation.
PKF has warned that HMRC’s extended programme of business records checks will ‘waste everyone’s time’, and suggested that HMRC staff employed on the programme could be put to ‘much better use’.
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.