Tax First March 2010
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March 2010
The Chancellor's Budget will take place on Wednesday 24 March 2010, and there is still much speculation around how 'voter-friendly' this Budget may be. For PwC's thoughts in advance of the Budget, you can visit www.pwc.co.uk/budget/.
In this issue we look at the recent announcement by the United States Internal Revenue Service (IRS) of a new initiative which requires specific companies to disclose information regarding uncertain tax positions as part of their tax return. We also highlight the discussion document published by HM Treasury and HM Revenue & Customs (HMRC) regarding the controlled foreign company (CFC) reforms.
We outline HMRC's views on capital distributions and dividends, with reference to the Tribunal finding in the First Nationwide case, and also flag up a potential opportunity for the recovery of VAT on business entertainment, following a decision by the Advocate General.
Following a recent ruling by the Court of Appeal, we examine the implications of the judgment, which states that a subsidiary whose shares have been pledged as security by its holding company is no longer a Companies Act 'subsidiary' of that holding company.
To round up this issue, we focus on a change to the deadline for all six year income tax and corporation tax claims, and also outline the findings of PwC's new Appetite for change report - a global survey of business leader's views on climate change and carbon policy.
