The Resource Beneficial ownership : U.K. court of appeal in the case of Indofood International Finance

Beneficial ownership : U.K. court of appeal in the case of Indofood International Finance

Label
Beneficial ownership : U.K. court of appeal in the case of Indofood International Finance
Title
Beneficial ownership : U.K. court of appeal in the case of Indofood International Finance
Creator
Subject
Language
eng
Summary
The concept of beneficial interest, in the context of benefits under tax treaties, has often intrigued tax administrators and courts throughout the world. The Court of Appeal of the United Kingdom recently had the occasion to deliver a judgment on this issue in the case of Indofood International Finance Limited vs. JP Morgan Chase Bank NA, London Branch, which is significant for various reasons. First, the said judgment, though rendered in the context of the applicability of tax treaty benefits, vis-à-vis beneficial interest, did not actually arise out of any tax case, but the same had its roots in a civil appeal. Secondly, although the said decision, while spelling out an unfavourable verdict in the context beneficial interest, vis-à-vis tax treaties, strongly pivoted on the peculiar facts of the case, yet, the Court of Appeal probably made some unnecessary remarks and comments, which are likely to ignite substantial debate and criticism among tax professionals across the world. This article provides a detailed analysis of the said decision
Citation source
In: Tax planning international review. - London. - Vol. 33 (2006),
http://library.link/vocab/creatorName
Mitra, R.K
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • beneficial ownership
  • case law
Label
Beneficial ownership : U.K. court of appeal in the case of Indofood International Finance
Instantiates
Publication
Label
Beneficial ownership : U.K. court of appeal in the case of Indofood International Finance
Publication

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