Interest double dip – Effect of anti-avoidance provisions

US Co. acquired UK Group in 2004, and a structure was put in place which allowed tax relief to be claimed in both the US and the UK in respect of interest on the financing costs.  Advice was sought on whether the structure was later caught by provisions introduced in the Finance (No. 2) Act 2005 to prevent avoidance involving tax arbitrage.

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VAT – Supplies by foreign universities

The UK campuses of an American university were operated by a partnership between that university and a Spanish educational establishment. The partnership was a UK limited liability partnership formed under the Limited Liability Partnerships Act 2000.

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Recoverability of VAT on legal fees

The US government was the plaintiff in proceedings taking place in Washington DC. A costs order on an indemnity basis had been made against them in the UK in relation to costs incurred by a litigation partner in a UK law firm in giving evidence under compulsion (in his capacity of legal adviser to one of the corporate defendants in the proceedings) for use at the US trial.

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