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Welcome to October’s edition of our UK Tax Round Up. In the UK, the First-tier Tribunal ruled in Dialog Semiconductor Ltd v HMRC that a $137 million break fee was not a chargeable gain, providing useful guidance on the tax treatment of termination payments. The Upper Tribunal also granted limited permission to appeal in Syngenta Holdings Ltd v HMRC, reopening important questions around the commercial purpose test and apportionment of interest deductions. At the EU level, the Council of the European Union announced its latest revisions to the list of non-cooperative tax jurisdictions, with Vietnam’s removal from Annex II and new commitments made by five jurisdictions to enhance tax transparency.
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