Wednesday, October 11, 2006

UK Draft Guidance on Beneficial ownership

When I commented, back in March, on the Indofood case, I was sure that a lot of water would still pass below the bridge construed by the controversial decision of the UK Court of Appeals. Some of this "water" has now came out into public, just two days ago, with the release of Draft Guidance on the UK Tax Authorities interpretation of the Indofood decision. This guidance was expected, based on the fact that the case has now became English Law, and is designed to cover the majority of situations where the controversial decision could give rise to uncertainty (e.g. every-day capital market transactions involving Special Purpose Vehicles). For me, I will read carefully the draft guidance (hopefully with critical eyes) and see what changes in the obscure world of (lack of) of beneficial ownership for tax purposes!


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