Cullen Group has been involved in a dispute with Inland Revenue, which claims it structured its affairs to avoid tax. Because Modena and Mayfair were not "associated persons" with the Cullen Group, the arrangements fell into the approve issuer levy (AIL) tax regime. Inland Revenue assessed Cullen Group as having avoided $59.5m of non-resident withholding tax in this manner, while it paid only $8m in AIL. But the judge backed Inland Revenue, saying that the group owes $51.5m in tax plus use-of-money interest and penalties. "The outcome of the High Court process is the result of hard work and dedication by the Inland Revenue team, Crown Law and counsel.

Source: Stuff March 12, 2019 03:00 UTC