Stephen Edge Slaughter and May discusses Indofoods an overseas dispute that has potential ramifications in the UK
Following the decision by the noteholders not to take the case on to the House of Lords we are left with a very unsatisfactory Court of Appeal decision on file. This decision may have important ramifications in the UK despite the fact that the underlying dispute did not relate to UK tax and did not involve UK taxpayers.
From comments made by senior HMRC officials the case is already perceived to be a potentially helpful blunt instrument that could effectively operate as a global anti-treaty-shopping provision for many securitisation and repackaging vehicles. City input may be needed to establish an acceptable modus operandi for such vehicles going forward — the crucial...
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Stephen Edge Slaughter and May discusses Indofoods an overseas dispute that has potential ramifications in the UK
Following the decision by the noteholders not to take the case on to the House of Lords we are left with a very unsatisfactory Court of Appeal decision on file. This decision may have important ramifications in the UK despite the fact that the underlying dispute did not relate to UK tax and did not involve UK taxpayers.
From comments made by senior HMRC officials the case is already perceived to be a potentially helpful blunt instrument that could effectively operate as a global anti-treaty-shopping provision for many securitisation and repackaging vehicles. City input may be needed to establish an acceptable modus operandi for such vehicles going forward — the crucial...
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:
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