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Company residence: 'central management and control': First-tier Tribunal decision

Global Tax Update: August 2017 / United Kingdom

This UK newsletter explains 5 topics including " Company residence: ‘central management and control’: First-tier Tribunal decision ". (Global Tax Update:August 2017/United Kingdom)

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1. Company residence: ‘central management and control’: First-tier Tribunal decision

The First-tier Tribunal has given an interesting decision on company residence in a case involving arrangements set up with a view to enabling the taxpayer group to augment capital losses.

2. Corporation tax loss relief reform: draft guidance

HMRC have published draft guidance in connection with the draft legislation to reform corporation tax loss relief to be included in the next Finance Bill, which is due to be published after the summer recess.

3. Corporate interest restriction: updated draft guidance

HMRC have published an updated version of their draft guidance on the corporate interest restriction in connection with the draft legislation to be included in the next Finance Bill.

4. VAT: SI 2017/0778: use and enjoyment of telecoms services

Further to the announcement in the Spring Budget, the VAT (Place of Supply of Services) (Telecommunications Services) Order 2017 has been laid before the House of Commons. The only material change from the draft Order published in May is that the new provisions will come into force from 1 November rather than 1 August.

5. VAT: MJ Hickey: penalties for delayed tax: Upper Tribunal

MJ Hickey Plant Hire and Contracts Ltd configured its accounting systems to exclude turnover from the final day of each quarter from its VAT returns. The turnover was included on the next VAT return, so this produced a cash flow advantage rather than avoiding VAT altogether. When they identified the error, HMRC issued a penalty for £149,186 for a deliberate inaccuracy.

 

>> Click for Japanese [法人の税務上の居住地国 :「管理支配地基準」: 簡易裁判所の判決] 

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