Irish Bank Resolution Corporation Ltd (in special liquidation) and Irish Nationwide Building Society v The Commissioners for HM Revenue and Customs: [2019] UKUT 0277 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Marcus Smith and Judge Herrington on 9 October 2019.

From:
HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
Published
9 October 2019
Category:
Tax
Release date:
9 October 2019

Read the full decision in Irish Bank Resolution Corporation Ltd (in special liquidation) and Irish Nationwide Building Society v The Commissioners for HM Revenue and Customs: [2019] UKUT 0277 (TCC).

CORPORATION TAX – UK branches of Irish banks – interest expense – whether deductible – attribution of notional capital – ICTA section 11AA(3)(b) – construction and application of UK – Ireland DTC.

Published 9 October 2019

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