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Anne Powell Senior PSL at Allen & Overy LLP considers the recent Special Commissioner case of Fletcher v HMRC
Archimedes must have felt a large degree of satisfaction as he sat in the public baths and discovered how to solve the problem of density. He is reputed to have been so delighted that he leapt out of the baths and ran naked down the streets shouting 'Eureka — I've found it!' I think we are probably all delighted to find that the Special Commissioner in Fletcher v HMRC [2008] UKSPC SPC00711 having doubted the question of whether a capitalisation of debt was structured as a rights issue at the hearing had inspiration after it and decided that...

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