Ross Fazzini Director Finestra Structured Finance London in the first of a two-part article discusses the Special Commissioners' decision in Prudential Plc v HMRC
This article considers the recently released decision of the Special Commissioners in Prudential plc v HMRC Spc 00636 regarding the tax-effectiveness of certain Tax-efficient Off Market Swap (TOMS) transactions entered into by Prudential the financial services group listed on the London Stock Exchange.
The case is important for several reasons.
● The sums involved are significant. Prudential was claiming tax deductions amounting to £105 million (potential tax at stake of £31.5 million at the 30% tax rate). In addition director general of HMRC Dave Harnett is reported to have said that...
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:
Ross Fazzini Director Finestra Structured Finance London in the first of a two-part article discusses the Special Commissioners' decision in Prudential Plc v HMRC
This article considers the recently released decision of the Special Commissioners in Prudential plc v HMRC Spc 00636 regarding the tax-effectiveness of certain Tax-efficient Off Market Swap (TOMS) transactions entered into by Prudential the financial services group listed on the London Stock Exchange.
The case is important for several reasons.
● The sums involved are significant. Prudential was claiming tax deductions amounting to £105 million (potential tax at stake of £31.5 million at the 30% tax rate). In addition director general of HMRC Dave Harnett is reported to have said that...
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:
