(1) Ardmore Construction Limited (2) Andrew Colin Perrin v The Commissioners for HM Revenue and Customs: [2015] UKUT 0633 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Morgan and Judge Berner on 20 November 2015.

Read the full decision in Ardmore Construction Limited and Andrew Colin Perrin v The Commissioners for HM Revenue and Customs: [2015] UKUT 0633 (TCC).

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.

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