The British Virgin Islands (BVI) tax scheme was complex. And the High Court judgement that ruled against it was equally complicated. The High Court had to consider whether the Appellant was actually trading. If the Appellant was not trading, but was instead engaged in a capital transaction, then no trading loss could occur which was claimable by the taxpayer, and so the Appellant would lose his case.  Second, the Court had to consider whether, by reason of a deeming provision, ie Section 812 of the Taxes Acts, the dividends in question remained treated as being owned by the BVI company…

Want to continue reading?

Introductory offer: Sign up today and pay €200 for an annual membership, a saving of €100.

Subscribe

Cancel anytime.

Are you already a member? .