BCM Cayman LP and Bluecrest Capital Management Cayman Limited v The Commissioners for HM Revenue and Customs [2022] UKUT 00198 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Leech and Upper Tribunal Judge Thomas Scott on 22 July 2022
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CORPORATION TAX – acquisition by Cayman Islands limited partnership of interest in UK limited partnership – liability of general partner in Cayman partnership to corporation tax on certain profit allocations – whether Cayman partner entitled to tax deduction for interest on borrowings to acquire interest in UK limited partnership – appeal dismissed.
Published 2 August 2022