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England and Wales decisions
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The Court of Appeal held that Article 12(5) of the UK-Ireland treaty did not disapply interest relief on the SAAD Claim, so HMRC’s appeal was dismissed.
Revenue And Customs v Burlington Loan Management DAC [2026] EWCA Civ 461 (20 April 2026)
The Court of Appeal held that Article 12(5) of the UK-Ireland treaty did not disapply treaty relief for BLM’s SAAD Claim interest, and dismissed HMRC’s appeal.
Nationwide Building Society v Bank of New York Mellon, London Branch & Anor [2025] EWHC 1046 (Comm) (01 May 2025)
The Commercial Court refused summary judgment on a contribution claim over unlisted notes, finding A&O had real prospects on alleged contractual and tortious duties. Nationwide’s amendment application was allowed, with costs against Nationwide.
Privy Council held the dividends were not artificial or fictitious and upheld treaty residence analysis for Barbados, allowing the appeal.
Houmet Trading Limited was not beneficially entitled to the interest within the meaning of s.933 ITA 2007 because its involvement was solely tax-motivated, ephemeral, and conferred no real or practical benefit; thus, the withholding tax exemption did not apply. Interest paid on loans of less than a year but routinely replaced by further loans from the same lenders was 'yearly interest' under s.874 ITA 2007, as the loans, viewed realistically, provided long-term funding.
Source excerpt
The Upper Tribunal dismissed HMRC’s appeal over whether assignment of a debt claim engaged Article 12(5) of the UK-Ireland treaty.
Hargreaves Property Holdings Ltd v Revenue And Customs [2024] EWCA Civ 365 (15 April 2024)
The Court of Appeal dismissed Hargreaves’ appeal on withholding tax, holding that Houmet was not beneficially entitled to interest assigned to it and that the loans gave rise to yearly interest.
The Upper Tribunal dismissed Hargreaves Property Holdings’ appeal on withholding tax, holding the interest was yearly interest arising in the UK and no relief applied.
Preliminary issues judgment on Danish dividend tax refund claims, holding that a contract to sell shares does not itself make the buyer a shareholder for tax purposes.
The Tribunal held that Article 12(5) of the UK-Ireland treaty did not apply to Burlington Loan Management DAC’s SAAD Claim interest, so withheld tax was repayable.
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