A selection of items from the corporate section of Ernst & Young's 2005 Budget Alert make it clear that the emphasis this year was strongly on combating avoidance both real and perceived
Avoidance through arbitrage
The Revenue is introducing some broad anti-avoidance legislation with the intention of countering arbitrage schemes that involve hybrid entities or hybrid instruments. The legislation takes effect from 16 March 2005.
The legislation is intended to apply where an arbitrage scheme using a hybrid entity or instrument results in:
● a double deduction for the same expense;
● a UK deduction for the payer in circumstances where the recipient is not taxed on the receipt; or
...
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A selection of items from the corporate section of Ernst & Young's 2005 Budget Alert make it clear that the emphasis this year was strongly on combating avoidance both real and perceived
Avoidance through arbitrage
The Revenue is introducing some broad anti-avoidance legislation with the intention of countering arbitrage schemes that involve hybrid entities or hybrid instruments. The legislation takes effect from 16 March 2005.
The legislation is intended to apply where an arbitrage scheme using a hybrid entity or instrument results in:
● a double deduction for the same expense;
● a UK deduction for the payer in circumstances where the recipient is not taxed on the receipt; or
...
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:
