A round up of other news this week.
On 22 May 2019, the Supreme Court passed its judgment in the Hancock v HMRC case, dismissing the appellant taxpayer’s appeal. The issue before the Supreme Court was whether section 116 of the TCGA applies to a transaction where both qualifying corporate bonds (QCBs) (which fall outside the charge to capital gains tax on redemption) and non-QCBs (which are within the charge to capital gains tax on redemption) are converted into other QCBs. The Court concluded that there were two separate conversions so the inherent gain in the non-QCB was taxable on redemption of the subsequent QCB.
On 20 May 2019, HMRC published the synthesised texts of the Multilateral Instrument (MLI) and the Double Taxation Convention of three different jurisdictions. Each of: the 2008 France-UK Double Taxation Convention; the 1969 UK-Finland Double Taxation Convention; and the 1997 UK-Singapore Double Taxation Agreement have been modified by the MLI. These updates follow the synthesised text of the Multilateral Instrument and the 2003 UK-Australia Double Taxation Convention published on 13 March.
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