Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual
Recent changes to the SDRT regime go against the drive to make UK asset management industry more competitive, writes Suzi Edwards, senior manager at PwC
For any transaction involving bonds or notes, there are a number of potential difficulties that may arise, which may include issues involving stamp taxes, VAT, withholding tax, FATCA, and the tax treatment of the bond issuer and bondholders. Eloise Walker and Abigail McGregor provide a handy practice guide for advisers
Natasha Kaye and Jacob Gilkes consider the EIS and stamp duty provisions which apply when introducing a new holding company
SDLT: time limit for amending a return
Simon Yeo and Billal Malik consider the judgment in St Matthews (West) Ltd and others v HMRC on the legality of retroactive legislation.
Retrospective legislation and ECHR
For private clients, this Budget was ‘one of the most disturbing of recent times’, writes Robert Field.