The winds of change
The OECD’s Forum for Harmful Tax Practices (FHTP) published its action 5 final report on 5 October 2015, as one of the 1...
Large Corporate
Large Corporate
To elect or not?
Many companies have recently moved, or are about to move, from preparing their accounts in accordance with UK GAAP (excl...
Negotiating the minefield
Gone are the days of tax directors resigning themselves to a job in the shadows.
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The new arena
Historically, intra-group financial transactions were generally subject to less tax authority scrutiny than those relati...
Raiders of the loss relief
In the early days of my tax career, nearly 25 years ago, there was a legislative provision that I thought a very useful ...
International exchange
HMRC have changed the way companies must comply with FATCA, clarifying the obligations including those under the common ...
Taking the credit
The research and development expenditure credit (RDEC) was introduced by the Finance Act 2013 and has led to a change in...
Raising taxes
Slowly the word crept out that there would be a great deal in the summer Budget – although details of the content remain...
Deductible relationships
A UK tax resident company has borrowed, so has a loan payable amount. Interest accrues on the loan.
The interest ratio
One action from the G20/OECD Base Erosion and Profit Shifting project – Interest Restrictions (action 4) – potentially a...