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Close Companies, Open Books: HMRC Consults On New Reporting Requirements For Close Companies
HMRC has proposed sweeping new reporting requirements for close companies that would mandate detailed disclosure of all transactions with participators, extending far beyond the current framework which only captures loans triggering tax charges. The consultation raises critical questions about the burden on privately-owned groups and private equity structures, where intra-group transactions could generate extensive reporting obligations despite no underlying tax liability.
United Kingdom Tax
M
Macfarlanes LLP
Article
The Role Of The Protector
The Privy Council has delivered a landmark judgment clarifying the role of fiduciary protectors in trust structures, determining that protectors with consent powers have broad discretionary authority rather than a narrow oversight function. This decision has profound implications for trust administration, potentially requiring protectors to undertake the same rigorous decision-making process as trustees themselves, raising questions about cost, practicality, and the risk of deadlock in trust governance.
United Kingdom Litigation
M
Macfarlanes LLP
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