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From Tax Talks on May 10, 2024
Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing arrangement, whether interest paid on intragroup loans was “yearly” and the recipient was “beneficially entitled” to it and on the approach that should be taken by the courts in constructing the hypothetical contract required to ascertain whether an individual should be treated as a deemed employee under the IR35 rules among other things.
April 2024
May 7, 2024
May 6, 2024