FCC 005019/2013

The case involved where taxation would be due for property which was in France but owned by companies, owned by companies which belonged via chain holdings to brothers who owned a Kuwaiti company.

Background

The applicant and his brother each owned half of the capital in a Kuwaiti company, which held shares in two separate companies, the remaining shares in the company were owned by the taxpayer and his brother. Property in France was held by both companies.

Decision