Koichiro Ohashi, Koji Yamamoto and Yoshiyuki Omori of White & Case describe fund distribution in Japan and analyse the article 63 exemption from business registration requirements which is increasingly being used by offshore managers as a resource-saving technique to distribute securities in Japan, and recent amendments to the securities law in relation to fund distribution to professional investors.
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A recent UK First-tier Tribunal decision highlights the broad application of an anti-avoidance rule to deny tax relief, say Robert Waterson and Matthew Cummings of Eversheds Sutherland
The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR