HMRC had been very concerned by Henderson J's decision in HMRC v Tower MCashback LLP1 where he had taken a very restrictive view of the scope of a closure notice. His decision on this point has now been overturned by the Court of Appeal (although the appeal by one of the partnerships was successful on other grounds).
Business Tax
Manufactured dividends paid under stock loan agreement
In First Nationwide v HMRC (TC00339 – 27 January) a UK investment company (F) had entered into an 'overseas securities lender's agreement' with a Netherlands bank...
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HMRC had been very concerned by Henderson J's decision in HMRC v Tower MCashback LLP1 where he had taken a very restrictive view of the scope of a closure notice. His decision on this point has now been overturned by the Court of Appeal (although the appeal by one of the partnerships was successful on other grounds).
Business Tax
Manufactured dividends paid under stock loan agreement
In First Nationwide v HMRC (TC00339 – 27 January) a UK investment company (F) had entered into an 'overseas securities lender's agreement' with a Netherlands bank...
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:
