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.
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