Her Majesty's Revenue and Customs issued guidance notes on the case between Indofood, a Thai food company, and JPMorgan Chase, a bank, following a Court of Appeal judgement in March. The case concerns Indofood's redemption of bonds sold through a Mauritian special purpose vehicle because of the withholding tax rate increasing above 10%. JPMorgan Chase, the bond trustee, argued that Indofood should have honoured the bonds and moved them to a Dutch special purpose vehicle to avoid the higher withholding tax.
October 16 2006