DOTAS: ‘tax advantage’ and counterfactuals in Hallmark 5

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) examines the Property 118 decision and the questions it raises about tax advantages, comparator transactions and the purpose tests in DOTAS Hallmark 5.

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DOTAS: ‘tax advantage’ and counterfactuals in Hallmark 5

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