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United Kingdom Case Law

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Tax law [2022] UKFTT 290 (TC)

Burlington Loan Management DAC v Revenue And Customs (INCOME TAX - appeal by the Appellant, an Irish resident company, against a refusal by the Respondents to repay to the Appellant income tax withheld at source)

Burlington Loan Management DAC v Revenue And Customs (INCOME TAX - appeal by the Appellant, an Irish resident company, against a refusal by the Respondents to repay to the Appellant income tax withheld at source) [2022] UKFTT 290 (TC) (22 August 2022)

The tribunal held Article 12(5) of the UK-Ireland treaty did not bar repayment of withholding tax on SAAD Claim interest.

  • Double tax treaties
  • Withholding tax
  • Interest income
  • Treaty anti-abuse provisions
  • Beneficial ownership
  • Double-tax-treaties
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Tax law [2022] UKFTT 112

JONATHAN OPPENHEIMER v Revenue & Customs (INCOME TAX - whether resident in UK or RSA - Article 4 of the Republic of South Africa/UK Double Tax Treaty 2002)

JONATHAN OPPENHEIMER v Revenue & Customs (INCOME TAX - whether resident in UK or RSA - Article 4 of the Republic of South Africa/UK Double Tax Treaty 2002) [2022] UKFTT 112 (TC) (24 March 2022)

The Tribunal allowed Jonathan Oppenheimer’s appeal, holding that his treaty residence under the UK/South Africa tax treaty was in South Africa.

  • Tax residency
  • Double tax treaties
  • Interpretation of treaties
  • Centre of vital interests
  • Habitual abode
  • Tie-breaker rules
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Tax law [2019] UKFTT 317 (TC)

McCabe v Revenue & Customs (VAT - capital goods) - whether to direct HMRC to disclose documents)

McCabe v Revenue & Customs (VAT - capital goods) - whether to direct HMRC to disclose documents) [2019] UKFTT 317 (TC) (20 May 2019)

The tribunal refused Mr McCabe’s request for HMRC to disclose documents from a UK-Belgium mutual agreement procedure on tax residence.

  • Disclosure of documents
  • Double tax treaties
  • Mutual agreement procedure
  • Residence for tax purposes
  • Case management powers
  • Tax-disclosure
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Tax law [2019] UKFTT 317

McCabe v Revenue & Customs (VAT - capital goods) - whether to direct HMRC to disclose documents)

McCabe v Revenue & Customs (VAT - capital goods) - whether to direct HMRC to disclose documents) [2019] UKFTT 317 (TC) (20 May 2019)

The First-tier Tribunal refused Kevin McCabe’s request for HMRC to disclose documents from a UK-Belgium mutual agreement procedure about his tax residence.

  • Disclosure of documents
  • Double tax treaties
  • Mutual agreement procedure
  • Residence for tax purposes
  • Case management powers
  • Tax-disclosure
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About this LexChat collection

United Kingdom decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.

Source links and collection timestamps are retained alongside the indexed records.