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The Privy Council dismissed Mauritius Revenue Authority’s appeal, holding that the relevant exemption turns on where the core activities generating the exempt interest income are carried out.
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 that Article 12(5) of the UK-Ireland treaty did not bar treaty relief on interest from the SAAD Claim assignment, so the withheld tax had to be repaid.
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.
Rusling v Revenue & Customs [2014] UKFTT 692 (TC) (18 July 2014)
The tribunal held that cleared post-dated cheques from a fraudulent investment scheme were taxable interest, upheld the discovery assessment, and split liability with Mrs Rusling.
Thomas v Revenue & Customs [2014] UKFTT 281 (TC) (17 March 2014)
A tax appeal over interest credited to a Cyprus escrow account was dismissed. The tribunal held the interest was taxable and confirmed the HMRC assessments.
Thomas v Revenue & Customs [2014] UKFTT 281 (TC) (17 March 2014)
The tribunal dismissed an appeal against income tax assessments on interest credited to a Cypriot escrow account linked to an overseas property purchase.
Euroceanica (UK) Ltd v Revenue & Customs [2013] UKFTT 313 (TC) (26 April 2013)
The Tribunal held that interest on cash collateral for ship-finance loans was generally within tonnage tax, but not for the Unicredit bareboat-charter period.
Coxon v Revenue & Customs [2013] UKFTT 112 (TC) (08 February 2013)
The tribunal dismissed Mr Coxon’s appeal against income tax assessments on escrow account interest, holding the interest was taxable and not covered by Part 8 relief.
Coxon v Revenue & Customs [2013] UKFTT 112 (TC) (08 February 2013)
The tribunal dismissed Mr Coxon’s appeal against tax assessments on escrow-account interest credited in Cyprus, holding the interest was taxable and not unremittable.
MM v Revenue & Customs [2011] UKFTT 807 (TC) (09 December 2011)
The tribunal held that MM was not trading and that, in the reality of a Ponzi-style loan scheme, he had not received taxable interest for the disputed years.
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