In the Hallminster decision (Case 250328), rendered on February 25 2004, the French Supreme Administrative Court had to decide whether a capital gain realized by a company resident in the UK from the sale of a majority shareholding in a civil company running a vineyard in France was subject to tax in France
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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