Sallesdesport

https://www.gov.uk › hmrc-internal-manuals › international-manual
This shows that the Court effectively adopted an international fiscal meaning of beneficial ownership in contrast to what it calls a narrow technical domestic law meaning

https://www.slaughterandmay.com › insights › imported...
The Court of Appeal has now upheld the decisions of the tribunal but has done so on a narrower basis than the Upper Tribunal it has decided the case based on long standing caselaw

https://www.simmons-simmons.com › ... › interest-and-beneficial-entitlement
The Court also agreed that the FTT had been correct to reject the argument that the concept of beneficial entitlement should be construed in accordance with the Court of Appeal

https://www.gov.uk › hmrc-internal-manuals › international-manual
Although in the context of DTCs beneficial ownership will take what the Court of Appeal decision accepted as an international fiscal meaning rather than a UK domestic meaning

https://www.lexology.com › library › detail.aspx
Since the Court of Appeal s decision in Indofood in 2006 the majority view has been that there are two different tests for beneficial ownership or entitlement one in respect of

https://www.pumptax.com › podcast › beneficial-entitlement-after-hargreaves
Discussion of Indofood and the ECJ cases in 2019 The international fiscal meaning has to take into account the objects and purposes of the Convention including avoiding double taxation

https://legalblogs.wolterskluwer.com › international...
Nonetheless the Court of Appeal declined to interpret beneficial entitlement in accordance with the approach taken by the Court of Appeal in Indofood on the basis that domestic

https://juristeca.com › uk › court-of-appeal-civil-division › sentencias
Instead the UT had wrongly applied the approach of the Court of Appeal in reversing Evans Lombe J s decision 2006 EWCA Civ 158 2006 STC 1195 which adopted an international fiscal meaning

https://www.europeantax.blog › post › ...
Since the Court of Appeal s decision in Indofood in 2006 the majority view has been that there are two different tests for beneficial ownership or entitlement one in respect of domestic law and one in