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Cross-border group relief claims: HMRC’s letter to claimants

Global Tax Update:May 2015/United Kingdom

HMRC have now decided their approach on pre 2006 cross-border group relief claims and started to issue letters to companies which are affected. The letter invites the company to consider withdrawing some of their cross-border group relief claims and asks for a response by 5 June 2015. (Global Tax Update:May 2015/United Kingdom)

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1. Cross-border group relief claims: HMRC’s letter to claimants

HMRC have now decided their approach on pre 2006 cross-border group relief claims and started to issue letters to companies which are affected. The letter invites the company to consider withdrawing some of their cross-border group relief claims and asks for a response by 5 June 2015.

2. New UK GAAP: effect on derivative contracts: deadline for election

One of the implications of adopting new UK GAAP is that many companies will be required to bring their derivative contracts onto the balance sheet for the first time and will then need to fair value the instruments each year. Unless specific hedge accounting can be adopted, these annual fair value movements will be recognised in the profit & loss account / income statement, without corresponding movements on the underlying hedged transaction. The basic analysis is that these movements will then be taxable, as will the transitional adjustments resulting from initial recognition of the instruments.

 

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