DSG Retail Ltd and others v Revenue and Customs Commissioners : [2009] UKFTT 31 (TC)

Resource Information

The work DSG Retail Ltd and others v Revenue and Customs Commissioners : [2009] UKFTT 31 (TC) represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

DSG Retail Ltd and others v Revenue and Customs Commissioners : [2009] UKFTT 31 (TC)

Contributor

• Baker, P

Subject

• group of companies
• case law
• captive insurance company
• tax avoidance
• transfer pricing

Language

eng

Summary

Judgment by the Special Commissioners dated 31 March 2009. This transfer pricing case concerns the reinsurance of risk with a captive insurance company in the Isle of Man. The taxpayer companies were part of a group of companies which was the largest retailer of electrical goods in the United Kingdom, comprising Dixons, Currys and PC World. DSG Retail Ltd was the retail company, and Dixons Insurance Services Ltd (DISL) was the group's insurance subsidiary. It was held that the provision made between DSG and DISL which consisted of the arrangement that DISL would insure or reinsure the extended warranty business written in DSG's stores on particular terms, was not at arm's length because if DISL had been independent it would have had to pay something to DSG

Citation source

In: International tax law reports. - London. - Vol. 11 (2009),

Geographic coverage

• European Union
• Europe

Language note

English