• UK Tax Treatment of Depositary Receipts: HMRC Will Still Treat ADR Holders as Beneficial Owners of Shares
  • May 24, 2012 | Authors: Emma Hardwick; Michael T. McGowan; Andrew Thomson
  • Law Firm: Sullivan & Cromwell LLP - London Office
  • HM Revenue and Customs lost the HSBC case on stamp duty reserve tax in February, but did succeed in arguing that the American Depositary Receipts concerned did not give their holders beneficial ownership of HSBC shares.