HMRC has republished its April 2012 guidance on stamp duty reserve tax (SDRT) repayment claims in respect of shares in UK companies issued to depositary receipt systems or clearance services located anywhere in the world. This followed the First-tier Tribunal decision in HSBC Holdings/Bank of New York Mellon and specified the statutory four-year time limit for claims. HMRC’s original January 2010 guidance following the ECJ decision in HSBC Holdings/Vidacos. Nominees covering issuers within the EU referred to the six-year time limit for claims which applied before April 2011..
Uzbekistan has become the latest jurisdiction to officially sign a Foreign Accounts Tax Compliance Act (FATCA) intergovernmental agreement (IGA) with the US. The Uzbekistan IGA is based on model 1B IGA. Uzbekistan previously reached an agreement in substance for a model 1A IGA with the US and has been treated by the US Treasury as having an IGA in effect from 30 June 2014.
The following has been published:
HMRC has republished its April 2012 guidance on stamp duty reserve tax (SDRT) repayment claims in respect of shares in UK companies issued to depositary receipt systems or clearance services located anywhere in the world. This followed the First-tier Tribunal decision in HSBC Holdings/Bank of New York Mellon and specified the statutory four-year time limit for claims. HMRC’s original January 2010 guidance following the ECJ decision in HSBC Holdings/Vidacos. Nominees covering issuers within the EU referred to the six-year time limit for claims which applied before April 2011..
Uzbekistan has become the latest jurisdiction to officially sign a Foreign Accounts Tax Compliance Act (FATCA) intergovernmental agreement (IGA) with the US. The Uzbekistan IGA is based on model 1B IGA. Uzbekistan previously reached an agreement in substance for a model 1A IGA with the US and has been treated by the US Treasury as having an IGA in effect from 30 June 2014.
The following has been published: