Tax News Highlights: December 2022

In this podcast, Zoe Andrews and Tanja Velling discuss the UK’s first comprehensive tax treaty with Brazil which was signed on 29 November 2022 as well as certain highlights from the Autumn Statement and in relation to the Autumn and Spring Finance Bills, including an update on the UK’s implementation of Pillar Two and the new Electricity Generator Levy to be legislated for in the Spring Finance Bill.

The podcast also covers two recent cases: the Court of Appeal’s decision in Centrica on the deductibility of advisory fees incurred in relation to the realisation of an investment as investment management expenses under section 1219 of the Corporation Tax Act 2009 and the Upper Tribunal’s decision in Kwik-Fit on the loan relationships unallowable purpose test in section 441 of the same Act. Zoe and Tanja further provide an update on the UK’s proposed replacement of its scaled-back DAC6 implementation and the National Audit Office Report on the Digital Services Tax.