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Absolutely nothing.
KEY POINTS
- Tribunal decides that nothing is something.
- Zero rate of tax is not the same as a tax exemption.
- Tax charge at 0% can sometimes be beneficial
- It would be easier to change a 0% tax rate than an exemption.
One of the key influencers in the early stages of my career was the highly respected Robert King. I learned a lot from him and we generally came to the same view about technical tax problems. But a rare disagreement has remained in my memory for what must be at least 20 years.
We were dealing with a group of companies and for reasons I cannot remember but I think must have had to do with losses it became necessary to demonstrate that a particular entity was an investment...
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