Weil Tax BLOG - Feed https://tax.weil.com/category/uk-tax/corporation-tax/ Views and developments from the Tax Department at Weil Fri, 24 Apr 2026 11:53:35 +0000 hourly 1 Face the Facts: another loan fails the unallowable purpose test https://tax.weil.com/insights/face-the-facts-another-loan-fails-the-unallowable-purpose-test/ Wed, 03 Jul 2024 14:33:35 +0000 Oliver Walker Erica Rees https://tax.weil.com/?p=2267 In JTI Acquisition Company (2011) Limited (“JTI”) v The Commissioners for His Majesty’s Revenue & Customs (“HMRC”) [2024] EWCA Civ 652, the Court of Appeal was asked whether JTI, a UK tax resident company, could bring into account debits in respect of interest payable on loan notes issued to a US group company for UK

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]]> In JTI Acquisition Company (2011) Limited (“JTI”) v The Commissioners for His Majesty’s Revenue & Customs (“HMRC”) [2024] EWCA Civ 652, the Court of Appeal was asked whether JTI, a UK tax resident company, could bring into account debits in respect of interest payable on loan notes issued to a US group company for UK

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]]> “Speedy” use of non-trading deficits leads to “Kwik” decision from the Court of Appeal on the unallowable purpose rule https://tax.weil.com/insights/speedy-use-of-non-trading-deficits-leads-to-kwik-decision-from-the-court-of-appeal-on-the-unallowable-purpose-rule/ Wed, 22 May 2024 14:05:46 +0000 Sean Wright Oliver Walker Erica Rees https://tax.weil.com/?p=2222 On Friday 3 May 2024, the Court of Appeal upheld the decisions of the First Tier Tribunal (“FTT”) and the Upper Tribunal (“UT”) in the case of Kwik-Fit Group Ltd and others v HMRC [2024] EWCA Civ 434, thereby dismissing the taxpayer’s appeal. The decision – the latest judgment concerning the UK’s “unallowable purpose” rule

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]]> On Friday 3 May 2024, the Court of Appeal upheld the decisions of the First Tier Tribunal (“FTT”) and the Upper Tribunal (“UT”) in the case of Kwik-Fit Group Ltd and others v HMRC [2024] EWCA Civ 434, thereby dismissing the taxpayer’s appeal. The decision – the latest judgment concerning the UK’s “unallowable purpose” rule

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]]> Ordinary share capital: HMRC shares its views https://tax.weil.com/uk-tax/straight-to-the-point/ordinary-share-capital-hmrc-shares-its-views/ Mon, 24 Sep 2018 15:14:49 +0000 Stuart Pibworth http://tax.weil.com/?p=503 For UK tax purposes, it is often necessary to determine whether shares constitute ordinary share capital (OSC). For instance, this might be necessary when considering, amongst others: a number of the group relief rules, such as corporation tax, capital gains tax and stamp duty the substantial shareholdings exemption the corporate dividend exemption entrepreneurs relief tax-advantaged

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]]> For UK tax purposes, it is often necessary to determine whether shares constitute ordinary share capital (OSC). For instance, this might be necessary when considering, amongst others: a number of the group relief rules, such as corporation tax, capital gains tax and stamp duty the substantial shareholdings exemption the corporate dividend exemption entrepreneurs relief tax-advantaged

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]]> Tales of the Unexpected: The Long Arm of the UK Hybrid rules https://tax.weil.com/uk-tax/uk-focus-latest-thinking/tales-of-the-unexpected-the-long-arm-of-the-uk-hybrid-rules/ Tue, 04 Sep 2018 15:08:20 +0000 Stuart Pibworth http://tax.weil.com/?p=500 The UK hybrid and other mismatch rules set out in Part 6A of the Taxation (International and Other Provisions) Act 2010 (TIOPA) (the Hybrid Rules) have been in force since 1 January 2017. So for 18 months now, UK taxpayers have been required to grapple with these rules and consider how they apply to their

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]]> The UK hybrid and other mismatch rules set out in Part 6A of the Taxation (International and Other Provisions) Act 2010 (TIOPA) (the Hybrid Rules) have been in force since 1 January 2017. So for 18 months now, UK taxpayers have been required to grapple with these rules and consider how they apply to their

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]]> Summer in the City: Draft UK Tax Legislation Published on 6 July 2018 https://tax.weil.com/uk-tax/corporation-tax/summer-in-the-city-draft-uk-tax-legislation-published-on-6-july-2018/ Fri, 13 Jul 2018 14:03:06 +0000 Stuart Pibworth http://tax.weil.com/?p=499 On 6 July 2018 the UK government published draft legislation expected to form the Finance Bill 2019 (the “Draft Legislation”), together with accompanying explanatory notes, tax information and impact notes and other ancillary documentation.  Publishing the Draft Legislation in the Summer, months before the introduction of the next Finance Bill, forms part of the Government’s

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]]> On 6 July 2018 the UK government published draft legislation expected to form the Finance Bill 2019 (the “Draft Legislation”), together with accompanying explanatory notes, tax information and impact notes and other ancillary documentation.  Publishing the Draft Legislation in the Summer, months before the introduction of the next Finance Bill, forms part of the Government’s

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]]> US Tax Reforms: Impact on Cross-border Investments https://tax.weil.com/uk-tax/straight-to-the-point/us-tax-reforms-impact-on-cross-border-investments-2/ Wed, 11 Jul 2018 09:36:56 +0000 Oliver Walker http://tax.weil.com/?p=498 The US Tax Cuts and Jobs Act of 2017 (2017 Act), generally effective for tax years beginning after 31 December 2017, enacted sweeping reforms to the system of US federal income taxation of cross-border investments. The focus of the reforms on cross-border taxation is, generally, on outbound investments by US headquartered multinational companies and moves

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]]> The US Tax Cuts and Jobs Act of 2017 (2017 Act), generally effective for tax years beginning after 31 December 2017, enacted sweeping reforms to the system of US federal income taxation of cross-border investments. The focus of the reforms on cross-border taxation is, generally, on outbound investments by US headquartered multinational companies and moves

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]]> Spring Statement 2018 https://tax.weil.com/uk-tax/budget-highlights-from-uk-fiscal-events/spring-statement-2018/ Wed, 14 Mar 2018 14:08:05 +0000 Oliver Walker http://tax.weil.com/?p=491 The 2018 Spring Statement took place on Tuesday 13 March 2018 and, as promised, did not contain any significant tax announcements.  However, the Government did take the opportunity to announce a number of consultations and calls for evidence. At his first Autumn Statement in 2016, the Chancellor announced that it would also be his last,

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]]> The 2018 Spring Statement took place on Tuesday 13 March 2018 and, as promised, did not contain any significant tax announcements.  However, the Government did take the opportunity to announce a number of consultations and calls for evidence. At his first Autumn Statement in 2016, the Chancellor announced that it would also be his last,

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