OrbitaxUKCourt of Appeal decides on residence status of foreign company re inter alia Netherlands-UK treaty
|Treaty Development|Netherlands-United Kingdom
The UK Court of Appeal gave its judgment on 27 January 2006 in the case of Wood v. Holden [2006] EWCA Civ 26 regarding a scheme to avoid UK capital gains tax on the sale of a controlling shareholding in a UK resident company. Details of the decision are summarized below.
(a) Facts and background. The scheme involved the taxpayers transferring their shares in the UK company to a comp…
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