Tax weekly highlights—1 September 2022

Table of contents

• Companies and corporation tax
• HMRC provides CIOT with update on pause and delays in R&D tax credit payments
• Devolution
• Memorandum of understanding between the Scottish Fiscal Commission and HMT has been published
• Business structures
• UT considers decisions of the First-tier Tax Tribunal (FTT) on the taxation of limited partnership transactions (BCM Cayman LP v HMRC; HMRC v BlueCrest Capital Management LP; Dodd v HMRC)
• International
• UK and ITV appeal to Court of Justice in CFC case
• OECD publishes comments on the progress report under Amount A of Pillar One
• Anti-avoidance

More sections of this document available when you sign-in to Lexis+ or register for a free trial.

Article summary

This week's edition of Tax weekly highlights includes: (1) the Memorandum of Understanding between the Scottish Fiscal Commission and HM Treasury, (2) HMRC’s reasons for pausing and delaying R&D tax credit payments and (3) the FTT’s decision that Burlington Loan Management (BLM) was entitled to use the exemption from UK withholding tax on interest provided by the UK-Irish DTT because neither it nor the Cayman seller of the debt had a main purpose of taking advantage of that withholding tax exemption.