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BENEFICIAL-INTEREST


The Upper Tribunal in Hargreaves effectively seeks to import the Indofood concept of beneficial entitlement into domestic law. Dominic Robertson (Slaughter and May) examines the practical uncertainties this creates and questions whether the decision was correctly decided.

Even by the standards of tax cases, the recent case of BlueCrest Capital Management Cayman Ltd & others v HMRC is a difficult read. However, it is worth persevering with, because HMRC has taken the opportunity to test out a number of theories on partnership taxation, with some fairly alarming results for taxpayers.

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