OrbitaxDraft guidance on application of Indofood case (interpretation of "beneficial ownership" under Indonesia-Netherlands tax treaty)
|Treaty Development|United-Kingdom
On 9 October 2006, HMRC issued draft guidance on its interpretation of the decision of the Court of Appeal in the case of Indofood International Finance Ltd v. JP Morgan Chase Bank N.A. London Branch [2006] EWCA Civ 158.
HMRC's view is that the Court of Appeal's decision is now part of UK law as regards double tax treaties and the adoption of an international fisca…
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