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Want to keep up with the latest developments in UK, EU and international tax? Tax News is a monthly series hosted by London-based tax lawyers Tanja Velling and Zoe Andrews, focussing on issues relevant to large UK and multinational businesses.
Episodes
Wednesday Oct 12, 2022
Wednesday Oct 12, 2022
In this podcast, Zoe Andrews and Tanja Velling discuss the First-tier Tribunal’s decision in Burlington Loan Management considering the purpose test in Article 12 (Interest) of the UK/Ireland double tax treaty and two decision of the Upper Tribunal: Aozora GMAC concerning the interaction between the UK/US double tax treaty and the UK’s rules on unilateral relief and Pickles considering the interpretation of “market value” and “new consideration” in the context of deemed distributions under section 1020 of the Corporation Tax Act 2010.
Zoe and Tanja also discuss the decision of the Inner House of the Court of Session in Ventgrove on the interaction between VAT law and the break clause in a lease, and the Advocate General’s opinion in Gallaher on the compatibility of the UK's group transfer rules with EU fundamental freedoms.
The podcast further considers the potential impact of the Retained EU Law (Revocation and Reform) Bill in the tax context as well as announcements made as part of the Growth Plan announced by the Chancellor on 23 September 2022, including proposals to reverse the planned increase in the rate of corporation tax, abolish the health and social care levy before it takes effect, undo the 2017 and 2021 changes to the IR35 rules and make the temporary £1 million level of the annual investment allowance permanent.