TaxWorldWeb – International Tax News

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For both borrowers and lenders, the UK tax regime for their financial transactions is broadly a case of applying old rules to new situations for which the rules were not intended. The themes of macro-economic structural change and the struggle for tax policy to cope with it are illustrated by the current tax treatment of, and HMRC’s proposed approach to, contingent convertible bonds. While the government is right to consult thoroughly on changes to existing legislation, the pace of change is still in many cases unnervingly slow and there are still too many situations where tax rules are driving the commercial deal.