(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 .
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.
Published 1 December 2016