In this podcast, Zoe Andrews and Tanja Velling discuss the Upper Tribunal’s decisions in JTI Acquisitions Company on the loan relationships unallowable purpose rule, Hotel La Tour on input tax recovery in respect of advisers’ fees on a share sale to raise funds for downstream economic activity, and M Group Holdings on the substantial shareholding exemption. They also discuss the First-tier Tribunal’s decision in Wilkinson on the unallowable purpose rule in the capital gains tax reorganisation rules.

The podcast further covers certain draft legislation for Finance Bill 2023-24 published on 18 July 2023, including the proposal for a single merged regime for tax reliefs for research and development, and provides an update on international tax reform, focussing the UK’s proposed implementation of the UTPR, and the QDMTT safe harbour and transitional UTPR safe harbour in the second tranche of Administrative Guidance published on 17 July 2023 by the Inclusive Framework.