The Upper Tribunal in Hargreaves effectively seeks to import the Indofood concept of beneficial entitlement into domestic law. Dominic Robertson (Slaughter and May) examines the practical uncertainties this creates and questions whether the decision was correctly decided.
The recent Upper Tribunal case of Hargreaves Property Holdings Ltd [2023] UKUT 120 (TCC) raises so many different withholding tax issues that it could be set as an exam question for future CTA students.
In an A* article in Tax Journal (‘Withholding tax: Hargreave-ances’ 23 June 2023) Deepesh Upadhyay and Sean Wright summarised the implications of the entire Hargreaves judgment. I don’t intend to retread the same ground: in this article I want to focus on the most difficult question in Hargreaves on whether a UK company was ‘beneficially entitled’ to interest income and therefore protected from withholding tax by ITA 2007 s 933 if that...
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The Upper Tribunal in Hargreaves effectively seeks to import the Indofood concept of beneficial entitlement into domestic law. Dominic Robertson (Slaughter and May) examines the practical uncertainties this creates and questions whether the decision was correctly decided.
The recent Upper Tribunal case of Hargreaves Property Holdings Ltd [2023] UKUT 120 (TCC) raises so many different withholding tax issues that it could be set as an exam question for future CTA students.
In an A* article in Tax Journal (‘Withholding tax: Hargreave-ances’ 23 June 2023) Deepesh Upadhyay and Sean Wright summarised the implications of the entire Hargreaves judgment. I don’t intend to retread the same ground: in this article I want to focus on the most difficult question in Hargreaves on whether a UK company was ‘beneficially entitled’ to interest income and therefore protected from withholding tax by ITA 2007 s 933 if that...
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:
