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Carried-forward losses on succession of a trade must be streamed and may be set against only that part of the successor’s trade arising from the succeeded trade according to the Court of Appeal’s construction of ICTA s343 in Leekes. Business looks beyond Brexit and continues to value the UK’s stable and competitive tax regime according to the latest tax competiveness report. The Coal Staff Superannuation Scheme Trustees Limited test case determines that the pre-2014 MODs regime was a restriction on free movement of capital, the remedy for which is repayment of the £8.8 million income tax equal to the relevant withholding tax deducted from the gross amount of the MODs. The government confirms it intends to publish consolidated versions of double tax treaties that have been amended by the MLI ‘in good time’ before the modifications take effect.
This article was first published in the 8 June 2018 edition of Tax Journal