UK Co. Holders Dodged Tax Via Bond Conversion, Panel Finds

Law360 (July 2, 2019, 8:36 PM EDT) -- A U.K. company’s shareholders took no risk in acquiring and converting a foreign bond, and their maneuver was designed to extract value and avoid taxation, a panel that reviews compliance with Britain’s anti-abuse tax rules said in opinions released Tuesday.

The General Anti-Abuse Rule Advisory Panel, an independent body that provides guidance to HM Revenue & Customs and to corporate and individual U.K. taxpayers, found that a company whose name was redacted had not been in a position to profit from its three shareholders’ scheme.

Devising and executing the bond-related tax arrangements were “not a reasonable course of action in relation...

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