Tax News Highlights: October 2023

In this podcast, Zoe Andrews and Tanja Velling discuss the Upper Tribunal’s decision in ScottishPower on the deductibility of payments made pursuant to an agreement with the regulator at the end of an investigation and the Supreme Court’s decision in Target Group on the scope of the VAT exemption for financial services. The podcast also covers draft legislation for Finance Bill 2023-24 in respect of the removal of the 1.5% stamp duty and SDRT charge on issues and transfers integral to capital raisings and further changes to the UK’s implementation of the Pillar Two GloBE Rules. Zoe and Tanja discuss the draft legislation for the transitional UTPR safe harbour and the QDMTT safe harbour, and how tax imposed under the Subject-to-Tax Rule fits within the GloBE rules. They further touch on developments in respect of the Multilateral Convention to Implement Amount A of Pillar One and the European Commission’s proposals for two new corporate tax directives concerning, respectively, the harmonisation of the corporate income tax base under the Business in Europe: Framework for Income Taxation (BEFIT) and the incorporation of the arm’s length principle and OECD Transfer Pricing Guidelines into EU law.