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The FTT’s decision in Warshaw shows that cumulative preference shares may, if they are also compounding, constitute ordinary share capital. The much-awaited draft regulations on the changes to the offshore receipts in respect of intangible property rules to ensure they are appropriately targeted at tax-motivated arrangements and robust against abuse are published alongside guidance on the rules. In Hancock, the Supreme Court dismisses a literal interpretation of the legislation as being contrary to Parliament’s intention. A no-deal Brexit may give financial businesses greater input VAT deductions than at present but concerns are raised about the lack of progress made on the UK’s long-term future relationship with the EU as regards financial services.
This article was first published in the 14 June edition of Tax Journal