The UK Inland Revenue has acted to close what it sees as a loophole in tax law that allows companies involved in international mergers and acquisitions to avoid a 1.5% tax. A number of recent transactions, including the BP/Amoco merger, the Astra/Zeneca merger and the Vodafone/Airtouch deal, were structured to benefit from an exemption which allowed the companies to avoid the 1.5% stamp duty reserve tax.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap