Revenue and Customs Brief 14/12
HMRC have confirmed in Revenue and Customs Brief 14/12 that their approach to determining who holds beneficial ownership of shares underlying depositary receipts has not changed following the First-tier Tribunal decision in HSBC Holdings & Bank of New York Mellon v HMRC.
In essence, they will continue to treat such receipts as conferring beneficial ownership as according to its established interpretation of the principles of English law.
