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Norfolk and Montagu on the Taxation of Interest and Debt Finance

Media of Norfolk and Montagu on the Taxation of Interest and Debt Finance
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Published: 01-01-2013
Format: Online Resource
Edition: 1st
ISBN: 9781784510169
Imprint: Bloomsbury Professional
RRP : £1,750.00

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Loren Epson

About Norfolk and Montagu on the Taxation of Interest and Debt Finance

A 12 month subscription for a single user licence priced at £1,750

Provides an authoritative, pragmatic and accessible guide to the taxation treatment of interest and debt finance for both individuals and companies.

Which key topics are covered?

what constitutes interest and whether interest is yearly;
withholding tax, the CRS, DAC and FATCA;
the taxation of employment-related and close company loans (including the disguised remuneration rules);
stamp tax, IHT, CGT and VAT treatment of interest and loans; and
the taxation of repurchase and stock lending arrangements.

What have recent releases covered?

the hybrid mismatch rules;
the interest restriction;
the pre, and post, 1 April 2017 loss relief rules;
P2P lending;
the 5 April 2019 loan charge;
the OECD Multilateral Convention on Double Taxation Agreements;
the Court of Appeal's decisions on UK source interest in Ardmore Construction v HMRC ([2018] EWCA Civ 1438) and on QCB redenomination in HMRC v Nicholas Trigg ([2018] EWCA Civ 17);
the Supreme Court's decision on restitutionary interest in Prudential Assurance Company v Commissioners for HMRC ([2018] UKSC 39);
the April 2018 IHT DOTAS hallmarks relating to debt finance;
the decisions of the GAAR Advisory Panel relating to loan-based disguised remuneration schemes; and
implications of the Data Protection Act 2018 and the EU (Withdrawal) Act 2018.
What will forthcoming releases cover?
Future releases will cover the Supreme Court's decisions on short interest in Anthony Lomas v HMRC and the CGT reorganisation provisions in Hancock v HMRC, as well as the Finance Act 2019.

When should you consult this resource?
The expert advice within this text is invaluable in a wide range of day-to-day scenarios, such as:

- advising a private client from an income tax, CGT or IHT perspective in relation to a borrowing or debt investment;
- determining whether interest has a UK source or whether a compensation payment could be subject to withholding tax;
- restructuring the borrowings of a group of companies; and
- consulting commentary on repealed provisions when considering how to respond to a 'follower notice'.

Want to see this online service in action?

To request a live demo from our expert team, or to sign up for a free trial, email or call 01444 416119. You can also contact our sales team to find out about subscription costs for more than 1 user.

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