Mark Middleditch (Allen & Overy) reviews recent developments affecting the City, including the consultation on interest expense and the corporation tax treatment of fines and related payments made by banks.
Your monthly round-up of tax issues affecting the City, by Mark Middleditch (Allen & Overy).
The Court of Appeal has handed down its judgment in the Prudential case, in what is hoped to be one of the final steps of this long lasting action between taxpayers invested in cross border portfolio holdings and HMRC. Simon Whitehead and Philippe Freund (Joseph Hage Aaronson), who acted for the taxpayers, summarise the outcome of this judgment and explain why it has taken so long.
Angela Clegg and Lucy Sauvage (BDO) look at the scope of the new legislation which introduces the requirement for large groups, companies and partnerships to publish their tax strategy annually.
Novation of derivative contracts between companies of the same group
The European Commission has published proposals for public CBCR. Heather Corben (King & Wood Mallesons) reviews the recommendations.