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Beneficial ownership and depositary receipts: HMRC guidance

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Revenue & Customs Brief 14/12 sets out the extent to which HMRC will continue to regard the holder of a depository receipt as having beneficial ownership of the underlying shares, following the First-tier Tribunal decision in the Stamp Duty Reserve Tax case of HSBC Holdings PLC and The Bank of New York Mellon Corporation v HMRC [2012] UK FTT 163. See www.lexisurl.com/3M6U9.

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