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Case Summary: Cullen Group Ltd v Commissioner of Inland Revenue

Cullen Group Ltd v Commissioner of Inland Revenue

The key facts and highlights of the High Court’s decision on the Cullen Group tax avoidance case.

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Cullen Group v IRD

The High Court has ruled that the Eric Watson controlled Cullen Group used a “web of entities” to avoid paying non-resident withholding tax of 15% on loans to other Watson controlled entities in the Cayman Islands, instead paying the Approved Issuer Levy rate of 2%.

Download our PDF here where we set out the facts of the case, followed by the highlights of the High Court’s decision.

Please contact Andrew Tringham in our Tax Disputes Resolution & Controversy team if you have any questions about this case.

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