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The Privy Council partly allowed Unicomer’s tax appeal, remitting the anti-avoidance and withholding tax issues, but dismissed the appeal on hire purchase income accrual.
The Privy Council held that dividends paid by Methanex Trinidad to its Barbados holding company were genuine, not artificial or fictitious, and qualified for treaty relief.
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.
Hargreaves Property Holdings Ltd v Revenue & Customs (CORPORATION TAX - whether interest paid by a UK resident company out of assets) [2021] UKFTT 390 (TC) (02 November 2021)
The tribunal held that interest had a UK source, was yearly in nature, and withholding exemptions did not apply on the facts. The appeal was dismissed.
Gelder Ltd v Revenue & Customs (INCOME TAX - Construction Industry Scheme) [2021] UKFTT 294 (TC) (18 August 2021)
The tribunal allowed Gelder Ltd’s appeal, finding it took reasonable care and made good-faith errors, so relief under regulation 9(3) was granted.
Gelder Ltd v Revenue & Customs (INCOME TAX - Construction Industry Scheme) [2021] UKFTT 294 (TC) (18 August 2021)
The First-tier Tribunal (Tax) allowed Gelder Ltd’s appeal, finding it had taken reasonable care and was entitled to relief under regulation 9(3) of the CIS rules.
Aozora GMAC Investments Limited v Revenue & Customs (CORPORATION TAX - interest paid by US subsidiary to UK parent company) [2021] UKFTT 99 (TC) (12 April 2021)
The Tribunal held that s793A(3) ICTA 1988 did not bar unilateral credit relief for US withholding tax because the US/UK treaty’s Article 23 was not an express denial of credit relief.
Aozora GMAC Investments Limited v Revenue & Customs (CORPORATION TAX - interest paid by US subsidiary to UK parent company) [2021] UKFTT 99 (TC) (12 April 2021)
The tribunal allowed Aozora’s appeal, holding that section 793A(3) ICTA 1988 did not bar unilateral credit relief for US withholding tax under the US/UK tax treaty.
Aozora GMAC Investment Ltd v Revenue And Customs (CORPORATION TAX - interest paid by US subsidiary to UK parent company) [2021] UKFTT 222 (TC) (12 April 2021)
The Tribunal held that Article 23 of the US/UK tax treaty did not expressly bar unilateral UK credit relief, so Aozora could claim relief under s790 ICTA 1988.
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