Gilt strips meaning

In this issue: General election 2024 Trusts Court of Protection HMRC Manuals updates Tax avoidance, evasion and non-compliance Insolvency—Private Client Contentious trusts and estates Pensions, insurance and tax efficient investments International Question of the week Additional Private Client updates this week Daily and weekly news alerts LexTalk®Private Client: a Lexis®PSL community New and updated content Dates for your diary Trackers Latest Q&A Useful information General election 2024 General Election 2024: tax aspects of manifestos The Liberal Democrat manifesto, ‘For a Fair Deal’, was issued on 10 June 2024. The Conservative and Unionist Party’s 2024 manifesto was released on 11 June 2024. The Green Party’s manifesto followed on 12 June 2024. The Labour Party manifesto was published on 13 June 2024. Each manifesto sets out the parties’ tax-related pledges should they prevail in the General Election on 4 July 2024. For more on the...

Watts v HMRC [2024] UKUT 168 (TCC) The arrangement broadly comprised the following principal stages: first, the taxpayer, funded by borrowings, purchased gilt strips valued at £1.5m; second, an option to acquire those strips was conferred on an interest in possession trust, of which the taxpayer was both settlor and life tenant, in exchange for a premium of approximately £1.35m, with an exercise price fixed at £150,000; third, the option relating to the gilt strips was assigned to Investec, a bank, for £1.35m, that amount being paid to the trustee of the trust; and finally, Investec exercised the option and made the corresponding payment of the £150,000 exercise price to the taxpayer. Invoking Finance Act 1996, Sch 13, para 14A, the taxpayer then claimed an income tax loss of £1.35m for the 2003/04 tax year...

In this issue Companies and corporation tax Employment taxes VAT International Anti-avoidance Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Companies and corporation tax Court of Appeal confirms a broad scope for the loan relationships unallowable purpose test (JTI Acquisition v HMRC) As covered in last week’s Tax weekly highlights, in JTI Acquisition Company (2011) Ltd [2024] EWCA Civ 652, the Court of Appeal (CoA) dismissed outright the taxpayer’s challenge to the disallowance, for corporation tax purposes, of debits for interest payable on the loan notes. The CoA concurred with the First-tier Tax Tribunal (FTT) and the Upper Tribunal (UT) that the company entered into the loan notes with an unallowable tax avoidance purpose under the loan relationships regime, and not for any genuine commercial rationale. See News Analysis: The Court of Appeal confirms a broad scope for the loan relationships unallowable purpose test (JTI...