Chris Bates and Judy Harrison consider the Supreme Court decision in DCC Holdings
The Supreme Court has given its judgment in HMRC v DCC Holdings (UK) Ltd ([2010] UK SC58). The case involved the complex interaction of the tax rules applying to transactions involving sale and repurchase of securities (repos) and the loan relationship rules. Although these rules have since been amended to avoid the difficulties found in this case the decision is an important one because it is the first complex tax case to be heard by the Supreme Court and will be seen as giving some guidance as to how the Court would approach similar cases in the future.
The rules in question relied on the creation of a statutory fiction under which parties to a repo transaction were deemed to have entered into loan relationships. The Court held that the statutory fiction could not be interpreted...
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Chris Bates and Judy Harrison consider the Supreme Court decision in DCC Holdings
The Supreme Court has given its judgment in HMRC v DCC Holdings (UK) Ltd ([2010] UK SC58). The case involved the complex interaction of the tax rules applying to transactions involving sale and repurchase of securities (repos) and the loan relationship rules. Although these rules have since been amended to avoid the difficulties found in this case the decision is an important one because it is the first complex tax case to be heard by the Supreme Court and will be seen as giving some guidance as to how the Court would approach similar cases in the future.
The rules in question relied on the creation of a statutory fiction under which parties to a repo transaction were deemed to have entered into loan relationships. The Court held that the statutory fiction could not be interpreted...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
