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 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.
- Double taxation treaty
- Withholding tax
- Interest income
- Treaty anti-abuse provisions
- Double-taxation-treaty
- Withholding-tax