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"Extreme shopping": HMRC legislation to counter treaty shopping: thoroughly draconian

  • Herbert Smith Freehills LLP
  • -
  • United Kingdom
  • -
  • August 5 2011

On 1 August, just before the summer break, HM Revenue & Customs (HMRC) published a "Technical Note" and draft legislation (together, the "Note") entitled "Tax Treaties Anti-avoidance"