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Purolite International Ltd v HMRC

In Purolite International Ltd v HMRC (TC 02151 – 9 August) two brothers (SB and DB) controlled a Delaware corporation (BC). They and BC each owned one-third of the shares in a UK company (BL) which owned 95% of the shares in another UK company (P). In 2000 the US government began legal proceedings against BC SB and DB for supplying goods to Cuba in violation of the Trading With the Enemy Act 1917 and the Cuban Assets Control Regulations. BC DB and SB were convicted on some of the charges against them: BC was fined $250 000 while DB and SB were each fined $10 000. P made a contribution of £3 807 294 to the legal costs which BC had incurred and claimed that this should be allowed as...

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