International update

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The High Court has recently agreed to a Group Litigation Order (GLO) following the European Court of Justice (ECJ) decision last year in the HSBC Holdings Ltd case (C-569/07) that the application of the special 1.5% Stamp Duty Reserve Tax (SDRT) charge is contrary to the Capital Taxes Directive. This decision created an opportunity to recover SDRT paid in certain circumstances such as where UK shares were issued to a depositary receipt issuer. This is good news for taxpayers and those affected should consider filing protective claims and potentially joining the new GLO if amounts are significant. Issuers onto US exchanges should also consider making claims as HMRC have confirmed that the case is challenging the rules wherever the clearing system is based and so will be covering issues such as SDRT on ADR (American Depositary...