10 May 2019
Mike Lane and Zoe Andrews consider HMRC’s revised hybrid capital instruments technical note and their response to stakeholders’ concerns on the profit diversion compliance facility. They also look at the full decision on the UK's CFC finance company exemption and the FTT decision in Oxford Instruments.
HMRC publishes a revised hybrid capital instruments technical note, which includes new commentary on takeover and change of control clauses. The EU Commission publishes its full decision on the UK’s CFC finance company exemption. The FTT decision in Oxford Instruments serves as a useful reminder of the limitation of tax rulings and that not all motive tests work in the same way. HMRC responds to stakeholders’ concerns about the profit diversion compliance facility.
This article was first published in the 10 May edition of Tax Journal.
Tax and the City Review May 2019
This material is provided for general information only. It does not constitute legal or other professional advice.
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