26 May 2023
Hargreaves Property Holdings Limited v HMRC [2023] UKUT 00120 (TCC)
The taxpayer appealed against assessments to income tax on the basis that the taxpayer had a duty to deduct withholding tax pursuant to s. 874 Income Tax Act 2007 (“ITA 2007”) (with the exception of certain de minimis amounts) on certain interest payments.
The Upper Tribunal rejected the tax payers’s appeal from the rejection of their appeal by the FTT. You can see a copy of the decision here.
Richard Vallat QC and Calypso Blaj appeared for HMRC; Patrick Way QC and Dilpreet Dhanoa of Field Court Tax appeared for the taxpayer.
This content is provided free of charge for information purposes only. It does not constitute legal advice and should not be relied on as such. No responsibility for the accuracy and/or correctness of the information and commentary set out in the article, or for any consequences of relying on it, is assumed or accepted by any member of PCTC or by PCTC as a whole.
