Michael Bell and Vicki Carr Corporate Tax Practice Osborne Clarke discuss the recent HMRC guidance following the Indofood decision and Stephen Edge Slaughter and May adds his comments
In our article 'Indofood — Christmas come Early?' (The Tax Journal Issue 854 25 September 2006) we bemoaned the lack of HMRC guidance following the case of Indofood and the effect that was having on transactions. The lack of HMRC guidance only served to fuel the climate of uncertainty. On 9 October 2006 HMRC finally published its long-awaited guidance on its interpretation of the Indofood decision.
The draft guidance provides a welcome safe harbour for the funding structures that fall within the examples it sets out. Practitioners are...
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Michael Bell and Vicki Carr Corporate Tax Practice Osborne Clarke discuss the recent HMRC guidance following the Indofood decision and Stephen Edge Slaughter and May adds his comments
In our article 'Indofood — Christmas come Early?' (The Tax Journal Issue 854 25 September 2006) we bemoaned the lack of HMRC guidance following the case of Indofood and the effect that was having on transactions. The lack of HMRC guidance only served to fuel the climate of uncertainty. On 9 October 2006 HMRC finally published its long-awaited guidance on its interpretation of the Indofood decision.
The draft guidance provides a welcome safe harbour for the funding structures that fall within the examples it sets out. Practitioners are...
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:
