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The Thin End of the Wedge?

Waseem Khokhar, Associate with DLA Piper's Tax Investigations and Disputes Group, comments on the recent Opinion of Advocate-General Geelhoed concerning the Thin Cap GLO

 
Waseem Khokhar Associate with DLA Piper's Tax Investigations and Disputes Group comments on the recent Opinion of Advocate-General Geelhoed concerning the Thin Cap GLO
 
On 29 June 2006 the much awaited Advocate-General's Opinion concerning the thin capitalisation (thin cap) group litigation was delivered; the Opinion had been postponed from the previous month. With billions potentially at stake and consequences likely to be relevant to most multinational companies (MNCs) it is a case worth keeping an eye on.
 
For some at least the Opinion is mildly encouraging but for others it is perplexing and disappointing. What is more if this Opinion together...

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