David Hughes 2

DAVID HUGHES considers whether a recent ECJ judgment is the final victory that puts a limit on European Community rights.

DAVID HUGHES reviews the High Court's decision in Wood v Holden.

Corporate residence can be a problematic area. A company may be resident overseas if it can show that its central management and control takes place outside the UK, but if a company only carries out a few transactions (such as the purchase or sale of subsidiaries), what level of involvement is needed to exhibit central management and control?

DAVID HUGHES considers the factors that determine corporate tax residence for the purposes of the Taxes Acts.

Alienation!

DAVID HUGHES BBS, MA (TCD), AITI, ACA, FTII considers the issue of whether a redemption of a non-qualifying corporate bond loan note constitutes an alienation under certain United Kingdom tax treaties.

DAVID HUGHES BBS (TCD), ACA, AITI, FTII, warns of the dangers of accepting floating rate loan notes in exit situations where business taper relief is at issue.

DAVID HUGHES BBS (TCD), ACA, AITI, FTII explains how a foreign currency clause could inadvertently turn a loan note into a qualifying corporate bond.

How are qualifying and non-qualifying corporate bonds distinguished for non-corporation tax purposes? DAVID HUGHES BBS (TCD), ACA, AITI, FTII has the solution.

WILL ALTERING THE terms of an existing loan note agreement trigger a disposal of that instrument for capital gains tax purposes? This article considers the changes which could be made, including extending the term of the loan note and revising the loan note's interest rate.