• Service: Tax, Global Indirect Tax, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 1/10/2014

United Kingdom - Dispute resolution, CFC financing, investment “white list” 

January 10: Recent tax developments in the United Kingdom include updates to tax dispute resolution policy, guidance concerning controlled foreign company (CFC) financing arrangements, and draft regulations expanding the “white list” for certain UK and offshore funds.

Tax dispute resolution policy

Two documents detailing HM Revenue & Customs (HMRC) governance arrangements for resolving tax disputes have been updated:

In particular, guidance on "multi-dispute cases" has been amended to allow HMRC in exceptional cases to consider whether litigation of a dispute would be cost-effective.

CFC guidance

HMRC on 2 January 2014 published guidance, CFC financing arrangements and application of section 441 CTA 2009, which considers the interaction between the finance company exemption in the CFC rules and the loan relationships “unallowable purpose” rule.

White list expansion

As announced in the United Kingdom's 2013 budget, draft regulations have been released to expand the existing “white list” of transactions to include traded life policy investments and carbon credits. The purpose of the white list is to provide certainty that returns from specified transactions on the white list will be treated as either investment income, or on disposal of the assets, as capital receipts.

Read a January 2014 report [PDF 843 KB] prepared by the KPMG member firm in the United Kingdom: Weekly Tax Matters (10 January 2014)

Also included in the report are the following developments:

  • Iveco Limited – Claims for bonus payments from 1 January 1978 to 31 December 1989
  • Consultation update – Value added tax (VAT) treatment of refunds made by manufacturers
  • Draft legislation issued on car tax
  • HMRC launch QROPS online service
  • Changes to employer payment booklets and letters
  • SDLT and de-enveloping properties

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