This new edition gives the reader expert guidance on the legislation surrounding loan relationships and derivative contracts which have undergone significant change in the last few years. The new edition combines the guidance given in the 10th edition and a Supplement published in 2020 to pick up the new rules on loss reliefs, and the corporate interest restriction restriction rules.
The 11th edition is further 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 2023 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.
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This well-established work offers comprehensive coverage of all aspects of the taxation of corporate finance, including loan relationships and derivative contracts, with particular emphasis placed on providing worked examples and planning guidance.
1. Company Finance: Debt and Equity
2. The Company Law Framework
3. The Accounting Framework
4. The Scheme of the Legislation
5. Legal Documentation of Debt
6. The Definition of Loan Relationships
7. Loan Relationships: General Computational Provisions
8. Loan Relationships: Special Computational Provisions
9. The Unallowable Purpose Rule
10. Interest
11. Capital Instruments
12. Gilts
13. Transfer Pricing
14. Corporate Interest Restriction
15. Losses
16. Controlled Foreign Companies
17. Special Companies
18. Derivative Contracts - Definition and Scope
19. Derivative Contracts - Computation of Taxable Profits
20. Embedded Derivatives
21. Crypto-assets
22. Foreign Exchange
23. Hedging and Deferral
24. Reorganisations and Reconstructions
25. Stock Lending and Repos
26. Islamic Finance
27. International Aspects
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.
