In JTI Acquisition Company (2011) Limited (“JTI”) v The Commissioners for His Majesty’s Revenue & Customs (“HMRC”) [2024] EWCA Civ 652, the Court of Appeal was asked whether JTI, a UK tax resident company, could bring into account debits in respect of interest payable on loan notes issued to a US group company for UK
On 17 November 2022, Chancellor Jeremy Hunt delivered his Autumn Statement, highlighting the government’s priorities of stability, growth and public services and remarking that the “path to growth” requires difficult decisions. Having already reversed many of the changes introduced by his immediate predecessor, Kwasi Kwarteng, in the short-lived September Mini Budget and Growth Plan 2022, the Chancellor has now announced further steps aimed at “delivering fiscal sustainability” and restoring the public’s confidence “at a time of significant economic challenge for the UK and the global economy”.
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In this article we examine recent developments that may affect the use of holding companies and the resulting impact on the UK as a holding jurisdiction.
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