HM Revenue & Customs have updated some key documents regarding resolution of tax disputes, and have provided new guidance on CFCs. The dispute resolution documents are the Code of Governance for resolving tax disputes; and Commentary on the litigation and settlement strategy. HMRC also published CFC financing arrangements and the application of section 441 CTA 2009 on 2 January 2014. This details the HMRC view of the interaction between the finance company exemption in the CFC rules and the loan relationships “unallowable purpose” rule.
Further, draft regulations have also been released to expand the existing “white list” of transactions which ensures that returns from specified transactions will be treated as investment income, or as capital receipts on disposal. The list will now include traded life policy investments and carbon credits.
