Stephen Edge Slaughter and May discusses the announcement in the Pre-Budget Report of a review into the way in which financial traders are allowed to claim relief for foreign tax credits
The announcement in the Pre-Budget Report of a review into the way in which financial traders are allowed to claim relief for foreign tax credits arising in the ordinary course of their business came at a rather odd time.
As many will know the Inland Revenue has been pursuing some parts of the financial sector vigorously on this topic (seeking to deny relief for foreign taxes suffered on the basis that there was no UK tax attributable to the particular transaction) for some years. Litigation is just about to start on what may become the test case.
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Stephen Edge Slaughter and May discusses the announcement in the Pre-Budget Report of a review into the way in which financial traders are allowed to claim relief for foreign tax credits
The announcement in the Pre-Budget Report of a review into the way in which financial traders are allowed to claim relief for foreign tax credits arising in the ordinary course of their business came at a rather odd time.
As many will know the Inland Revenue has been pursuing some parts of the financial sector vigorously on this topic (seeking to deny relief for foreign taxes suffered on the basis that there was no UK tax attributable to the particular transaction) for some years. Litigation is just about to start on what may become the test case.
...
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