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Period to 21 September 2017

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

Budget date announced - Wednesday 22 November 2017
The Chancellor of the Exchequer, Philip Hammond, has announced that the Government will publish its Autumn Budget on Wednesday 22 November 2017.

Upper-tier Tribunal rules that shares with no dividend rights are ordinary share capital
The Upper-tier Tribunal has ruled that shares with no dividend rights are ordinary share capital (OSC) as defined in s989 ITA 2007, overturning the earlier decision of the First-tier Tribunal (FTT). This decision, in line with previous case law (notably Castledine) and HMRC practice, therefore removes the ambiguity the earlier FTT decision gave rise to.

Finance Bill 2017-2019: Change to penalty rules for errors in taxpayers’ documents
Finance Bill 2017 Clause 64, published on 8 September, introduces amendments to schedule 24 of Finance Act 2007 which covers penalties for errors.