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Corporate taxes
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Corporate taxes
CORPORATE TAXES
Hybrids and dual inclusion income: are we there yet?
Richard Milnes
Fehzaan Ismail
Richard Milnes and Fehzaan Ismail (EY) assess the concept of dual inclusion
income under the UK hybrid provisions following a prolonged period of
iterative change.
No joy for JTIAC: an extension of the unallowable purpose principle
Constantine Christofi
The last in a trilogy of recent Court of Appeal cases on ‘unallowable purpose’ has seemingly extended its ambit yet further, writes Constantine Christofi (EY).
The CIR and related party guarantees: a case study for a privately owned UK group
Robert Langston
Robert Langston (Saffery) provides a practical case study on the operation
of the corporate interest restriction where related party guarantees and
withholding tax issues are involved.
A cautionary tale: how to fail to show accounts are GAAP-compliant
Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) examines the recent decision in
Barclays Bank Plc v HMRC
.
The impact of Pillar Two on tax risk apportionment for a corporate sale
Anne Powell
Anne Powell (Bryan Cave Leighton Paisner) considers how our historic experience of tax covenants steer us to resolve new Pillar Two risks.
Writing off a loan: the unallowable purpose trap
Mark Whitehouse
Mairead Cummins
Tax Journal
’s recent coverage of the
Keighley
case has largely focused on connected companies issues. Here, Mark Whitehouse and Mairead Cummins (PwC) focus on the other key issue in that case: the ‘gateway test’ for the deductibility of loan relationship debits.
Difficult choices: disguised remuneration in the context of corporate insolvency
Jon Preshaw
Ben Proctor
Significant employment tax charges can arise in certain insolvency situations
where there was never an intention for rewards to be provided in connection
with employment, write Jon Preshaw and Ben Proctor (Jon Preshaw Tax).
Tax and the City review for February 2024
Zoe Andrews
Mike Lane
The Court of Appeal’s decision in
Dolphin Drilling
and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Tax clouds on the Horizon for the Post Office?
Heather Self
Heather Self (Blick Rothenberg) considers the tax issues surrounding compensation payments made by the Post Office to subpostmasters.
On purpose: developments in the main purpose test
Oliver Walker
Akash Mehta
Oliver Walker and Akash Mehta (Weil, Gotshal & Manges) consider the
current status of the TCGA 1992 s 137 main purpose test.
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of
300
EDITOR'S PICK
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
1 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
2 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
3 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
4 /7
2024: that was the year that was
Jemma Dick
5 /7
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
6 /7
The tractor tax
Stuart Maggs
7 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
The tractor tax
Stuart Maggs
NEWS
Read all
Salaried members: HMRC reverses position on the TAAR and Condition C
Tax sites designated in East Midlands investment zone
SAYE scheme bonus rates updated
Land transaction tax: subsidiary dwelling exemption
Tax system costs billions in administration, says NAO
CASES
Read all
Lloyds Asset Leasing Ltd v HMRC
S Fitzgerald and another v HMRC
Sarabande v HMRC
Another case that caught our eye: 14 February 2025
M Ashley v HMRC
IN BRIEF
Read all
Salaried members update
Themes in UK corporate tax disputes for 2025 (and beyond)
JVs and the top-up taxes: does HMRC’s draft guidance bring clarity?
Reflections on the Budget fallout – three months on
BlueCrest: the CA ruling on Condition B
MOST READ
Read all
Tweaking the Temporary Repatriation Facility
Bryan Robson Ltd v HMRC
UK suspends Russia and Belarus Double Tax Treaties
ScottishPower: payments under settlement agreements
Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC