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Two weeks to 1 May 2020

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.

Responding to the business impacts of COVID-19
As the international response continues, how can you prepare your organisation and respond? Visit our global crisis centre webpage and our COVID-19 hub on TheSuite continue to keep up to date on this topic.  Of particular relevance to multinational companies operating in the UK:

Consultation extension to 29 August
In recognition of the significant disruption many stakeholders are facing due to COVID-19, HMRC and HM Treasury have extended the deadlines for responses to ten tax policy documents by three months - including those on hybrid and other mismatches and the taxation impacts arising from the withdrawal of LIBOR. Read more and see the full list here.

Ladbrokes & Union Castle Mail Steamship v HMRC - Court of Appeal decision
The Court of Appeal has handed down its judgment in these cases, dismissing both taxpayer groups’ appeals and, in the Union Castle case, allowing HMRC’s cross-appeal on the ‘fairly represents’ points.  It includes a useful discussion and summary of the case law history on the meaning of ‘fairly represents’. Read the full judgment here.