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BLOG: Fourth tranche of Pillar Two Administrative Guidance: all clear for securitisations? Securitisation is a form of structured financing, whereby the credit risks associated with a specific pool of assets are segregated from the originators’ own credit risks. This is typically achieved by establishing a special purpose vehicle (SPV), which...
Tax and the City Review - June 2024 In another case involving both commercial and unallowable purposes, the Court of Appeal in Kwik-Fit decides that some of the loan relationship debits can be allocated to the commercial purpose. In a blow to taxpayers, the Court of Appeal in Hotel La Tour...
BLOG: Lessons learned from JTI and other recent unallowable purpose cases The main lesson to be learned is that it all depends on the specific facts and how they are presented to the fact-finding tribunal! JTI is the third unallowable purpose case decided by the UK Court of Appeal this year, the previous two being BlackRock and...
BLOG: Change: Labour Party Manifesto 2024 Latest polling figures for the UK’s general election on 4 July continue to indicate a change in government as Labour, the main opposition party, enjoys a c. 20 percentage point lead over the Conservative Party which has governed the UK since 2010. What...
Podcast: Tax News: June 2024 In this podcast, Zoe Andrews and Tanja Velling discuss the Upper Tribunal’s decisions in the remuneration trust case Marlborough DP and the VAT classification case Innovative Bites. In considering the latter, Zoe and Tanja also touch on a recent IMF paper...
BLOG: Good news for secondary debt markets in interest withholding tax case before UK Upper Tribunal HMRC v Burlington Loan Management DAC is an important decision for the smooth running of secondary debt markets. It is also a helpful precedent for tax authorities, taxpayers and tax advisers alike as they spend more time in the future considering when an...
Hargreaves in the Court of Appeal: A return to orthodoxy on withholding taxes? The Court of Appeal has dismissed Hargreaves’ appeal against the Upper Tribunal’s decision and determined that tax should have been withheld from interest paid on loans advanced to the group. The judgment provides taxpayers and their advisers...
BLOG: VAT recovery on shares sale: no special rule for fundraising transactions The UK Court of Appeal’s decision in Hotel La Tour has dashed taxpayers’ hopes of being more readily able to recover VAT paid on deal fees in respect of share sales. It is possible that the taxpayer may seek to appeal to the Supreme Court (after all, the...
BLOG: Tax Disputes Podcast: France I’m sad to say we have reached the end of our round the world Tax Disputes podcast series but we are going out in style with a trip to Paris for a stimulating conversation between myself, my colleague, tax partner Charles Osborne and Julien Gayral, tax...
BLOG: Challenging dawn raids in the UK HMRC raided the London offices of a global financial brokerage business and the home of a former employee on 28 September 2022, following requests for assistance from Germany and Denmark for criminal investigations in respect of cum-ex trades. The...
BLOG: Tax Disputes Podcast – Nigeria Our “trip” through tax disputes landscapes around the world is sadly nearing its end (and by “trip”, I mean a six-part podcast series on tax disputes in G20 countries across six continents). This stop in Nigeria marks the penultimate episode in the series...
Tax and the City Review - May 2024 Mike Lane and Zoe Andrews discuss: the Court of Appeal’s decisions in BlackRock (unallowable purpose and transfer pricing) and in Hargreaves Property (withholding tax on interest); changes to HMRC’s stamp taxes on shares guidance on the...
Global Investigations Bulletin (May 2024) Our latest Global Investigations Bulletin for May 2024 is now available. This month we discuss the FCA finally setting out its findings against Link Fund Solutions in the latest instalment of the Woodford saga. We also set out recent news in global...
BLOG: Tax Disputes podcast - India In the fourth episode of our round the world Tax Disputes podcast series, we take you to India for a conversation with Mukesh Butani, founder and Managing Partner of BMR Legal Advocates, Sarah Osprey, tax partner and member of Slaughter and May’s Tax...
Podcast: Tax News: May 2024 In this podcast, Zoe Andrews and Tanja Velling discuss two Court of Appeal decisions on the loan relationships unallowable purpose rule in section 441 of the Corporation Tax Act 2009: BlackRock and Kwik-Fit.