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Articles

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United Kingdom Unallowable Purpose Rule Denies Interest Deductions in “Tower” Structure

United Kingdom - April 30 2019 A UK court has ruled that a company was not entitled to a tax deduction for interest expenses arising within a "tower" financing structure because the...

James A.D. Wilson, Patrick J. O'Gara.

Unallowable purpose rule denies interest deductions in tower structure

United Kingdom - April 26 2019 A UK court has ruled that a company was not entitled to a tax deduction for interest expenses arising within......

James A.D. Wilson, Patrick J. O'Gara.

HMRC's new facility offers an opportunity for multinationals to bring their transfer pricing in line with HMRC's expectations, avoiding the burden of an HMRC-led investigation

United Kingdom - January 14 2019 HMRC has launched a new Profit Diversion Compliance Facility (PDCF), intended to encourage multinationals with arrangements potentially within the...

Kate Alexander, Richard Fletcher, Nigel M. Dolman, Patrick J. O'Gara.

HMRC's new facility offers an opportunity for multinationals to bring their transfer pricing in line with HMRC's expectations, avoiding the burden of an HMRC-led investigation

United Kingdom - January 11 2019 HMRC has launched a new Profit Diversion Compliance Facility (PDCF), intended to encourage multinationals with arrangements potentially within the...

Kate Alexander, Richard Fletcher, Nigel M. Dolman, Patrick J. O'Gara.

Bringing tax into the boardroom

United Kingdom - October 30 2015 New proposals will mean increased compliance burdens for large businesses and a broader range of information sources available to HM Revenue &...

Paula Ruffell, Alex Chadwick.