The comments of the First-tier Tribunal in the HSBC case about whether the holder of an ADR has a beneficial interest in the underlying shares have caused concern. If the FTT’s views were to be applied more widely, they would cause significant tax problems. It appears that HMRC is prepared to take a pragmatic approach here.
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The comments of the First-tier Tribunal in the HSBC case about whether the holder of an ADR has a beneficial interest in the underlying shares have caused concern. If the FTT’s views were to be applied more widely, they would cause significant tax problems. It appears that HMRC is prepared to take a pragmatic approach here.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: