Executive summary
In 2008, a United Kingdom (UK)-resident entity received a dividend distribution from shares it held in a Swiss entity. These shares had been acquired to hedge derivative contracts in the course of the UK-resident entity’s standard business. Under the derivative contracts, a series of payments from the UK-resident entity to its clients were agreed. Inter alia, a settlement interest payment in the amount of withholding tax(es) levied was agreed, provided certain conditions were me…