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Practical Experience of the Arbitrage Rules

Anneli Collins and Michael Bird of KPMG's International Corporate Tax group discuss their experience to date in applying for clearances under the new arbitrage rules
The arbitrage rules which were introduced last year are aimed at countering tax avoidance schemes that involve hybrid entities or hybrid instruments. Sarah Luder's article Hybrid Financing (The Tax Journal Issue 810 24 October 2005) outlines the rules in more detail. The purpose of this article is to give an update on their practical application and in particular our experiences of the informal clearance process.
Readers will recall that there are two parts to the legislation which is set out in F(No 2)A 2005 ss 24 to 31. Where the first part applies it denies a...
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