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Full Description
This relaunched title (previously titled Taxation of Loan Relationships and Derivative Contracts) gives the reader expert guidance on the tax legislation surrounding corporate finance transactions, which have undergone significant change in the last few years.
The commentary is enhanced by the inclusion of a new section dealing with crypto-assets; a new section on Gilts, including commentary on liability driven investment (LDI); an expanded chapter on Islamic finance, and new chapters covering the company law framework for this area of work; and the legal documentation of debt.
The relevant provisions of Finance Acts 2021 to 2024 are covered, including the changes to the transfer pricing rules from April 2023. New guidance from HMRC and relevant case decisions is also included.
David Southern KC specialises in commercial tax, including direct tax, VAT and pension schemes, and all forms of tax litigation, including tax investigations and judicial review.
Contents
1. Corporate Finance
2. The Accounting Framework
3. The Company Law Framework
4. The Tax Framework
5. The Legislative Framework
6. The BEPS Project
7. Loan Relationships: definition and scope
8. Loan Relationships: computational provisions
9. Securities and Hybrids
10. Cryptoassets
11. Interest
12. Corporate Interest Restriction
13. Loss Relief
14. Derivatives: definition and scope
15. Derivatives: computational provisions
16. Embedded derivatives
17. Foreign exchange
18. Hedging and deferral
19. Reorganisations
20. Reconstructions
21. Special companies
22. Islamic finance
23. Stock lending and repos
24. Transfer pricing
25. International dimension
