20 November 2015
UT Decision: Ardmore Construction Limited & Andrew Colin Perrin v HMRC
INCOME TAX-deduction of tax at source-whether “interest arising in the United Kingdom” – ITA 2007, s 874-source of interest-test to be applied-whether a multi-factorial test, a test of nationality of the loan document or a place of credit test-National Bank of Greece considered-appeals dismissed.
Richard Vallat instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents.
Click here for the full decision.
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.