The Court of Appeal saw no basis on which it could properly interfere with the Upper Tribunal’s practical application of the multifactorial test to determine a UK source of interest in Ardmore. Professional advisers and their clients are considering how to track potentially reportable cross-border arrangements from 25 June 2018 under the new EU intermediaries rules. The Supreme Court in Project Blue Limited demonstrates that FA 2003, s75A is a novel type of anti-avoidance rule, the purpose of which is to correct insufficiencies of tax. HMRC updates its 2016 guidance for large businesses on publishing their tax strategy. The decision in the Netherlands to abolish deductions for the coupons on contingent convertibles (CoCos) issued by banks and insurers with effect from 1 January 2019 based on concerns about State aid creates uncertainty for banks, insurers and their investors.
This article was first published in the 13 July 2018 edition of Tax Journal.
