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UK: Unallowable purpose rule for loans, small and medium-sized enterprise R&D regime, stamp duty land tax payment and filing obligations

Summaries of recent court decisions

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November 7, 2024

The KPMG member firm in the UK prepared reports on three recent court decisions:

  • The Supreme Court declined to hear appeals from three lower court decisions regarding the rule under which the deductibility of interest on loans with an “unallowable purpose” may be denied. Read a November 2024 report
  • The First-tier Tribunal held that the taxpayer’s research and development (R&D) activities were not “subsidized” or “subcontracted” and thus the taxpayer’s claim qualified under the small and medium-sized enterprise (SME) R&D regime. Read a November 2024 report
  • The First-tier Tribunal held that stamp duty land tax payment and filing obligations are triggered based on “substantial performance” only when the purchaser occupies the property by agreement with the vendor and as if the purchaser had become the owner of the property. Read a November 2024 report

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