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Effective place of management (Lee and Bunter v HMRC)

Effective place of management (Lee and Bunter v HMRC)
Published on: 03 May 2017
Published by: LexisPSL
  • Effective place of management (Lee and Bunter v HMRC)
  • Original news
  • What are the practical implications of this case?
  • What was this case about?
  • Round-the-world schemes
  • Place of effective management
  • Focus of a double tax treaty is on liability to tax, not the identity of the person
  • What were the facts?
  • What were the issues to be decided?
  • What did the FTT decide?
  • More...

Article summary

Tax analysis: The First-tier Tax Tribunal (FTT) has found that the place of effective management of two settlements was the UK and as a result, capital gains tax (CGT) was payable on the gains made on the sale of shares. Although the facts of this case are not that interesting, this case provides a useful discussion on the meaning of place of effective management. or take a trial to read the full analysis.

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