EWCA 622 (2009) Prudential v HMRC

June 29th 2009

Tax Planning; Currency Contracts - HMRC Won

Case Summary:

Prudential claimed relief for front end payments in connection with foreign exchange hedging transactions. HMRC said deductible qualifying payments do not include the principal paid on the acquisition or sale of foreign currency. They were no more than prepayments of part of the final exchange of principal under the hedging agreements. The Court agreed with HMRC.