In Equity Trust (Singapore) Ltd v HMRC (Ch D – 20 May) a Singapore company (E) was the trustee of a pension scheme (R).
In November 2006 HMRC recognised R as a ‘qualifying recognised overseas pension scheme’ within FA 2004 s 150(8).
In January 2008 HMRC withdrew that recognition. E subsequently took proceedings in the Ch D.
The Ch D dismissed the proceedings and gave judgment for HMRC. HHJ Hodge QC held that the Singapore Income Tax Act 1948 s 5 provided a system for the approval or recognition of Singapore pension schemes by the Singapore Inland Revenue Authority.
It appeared that R failed to meet the requirements of that system because R’s marketing literature appeared ‘to proceed on the footing that Singapore residents will not be admitted’ and E and R seemed to have been involved...
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In Equity Trust (Singapore) Ltd v HMRC (Ch D – 20 May) a Singapore company (E) was the trustee of a pension scheme (R).
In November 2006 HMRC recognised R as a ‘qualifying recognised overseas pension scheme’ within FA 2004 s 150(8).
In January 2008 HMRC withdrew that recognition. E subsequently took proceedings in the Ch D.
The Ch D dismissed the proceedings and gave judgment for HMRC. HHJ Hodge QC held that the Singapore Income Tax Act 1948 s 5 provided a system for the approval or recognition of Singapore pension schemes by the Singapore Inland Revenue Authority.
It appeared that R failed to meet the requirements of that system because R’s marketing literature appeared ‘to proceed on the footing that Singapore residents will not be admitted’ and E and R seemed to have been involved...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
