The Resource Aozora GMAC Investments Ltd v Revenue and Customs Commissioners : [2021] UKFTT 99 (TC)

Aozora GMAC Investments Ltd v Revenue and Customs Commissioners : [2021] UKFTT 99 (TC)

Label
Aozora GMAC Investments Ltd v Revenue and Customs Commissioners : [2021] UKFTT 99 (TC)
Title
Aozora GMAC Investments Ltd v Revenue and Customs Commissioners : [2021] UKFTT 99 (TC)
Creator
Contributor
Subject
Language
  • eng
  • eng
Summary
Judgment by the First-tier Tribunal (Tax), decision date 12 April 2021. This is the First-tier Tribunal's determination of the appeal which was the subject matter of a previous judicial review application reported in (2019) 22 ITLR 191. This case discussed the application of a provision of UK domestic law, paragraph 793A of the Income and Corporation Taxes Act 1988, which was added in the year 2000, and which inserted a restriction on the availability of unilateral relief by credit for foreign taxes. The issue in the case concerns whether or not unilateral relief by way of credit for US tax is available to a company which is excluded from the provisions of the UK-US double taxation convention under the limitation on benefits clause. The judgment of the First-tier Tribunal ventilated various issues, but the key conclusion is that the provision in the limitation on benefits article, under which the taxpayer was denied the exemption from withholding tax on interest in the US, was not an 'express provision' within the scope of art. 793A
Citation source
In: International tax law reports. - London. - Vol. 23 (2021), part 5 ; p. 808-841
http://bibfra.me/vocab/relation/comm
wgxhYUYtE4w
http://library.link/vocab/creatorName
Avery Jones, J.F
Geographic coverage
Europe
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • LoB
  • tax treaty
  • foreign tax credit
Label
Aozora GMAC Investments Ltd v Revenue and Customs Commissioners : [2021] UKFTT 99 (TC)
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2021/G-I/ITLR/vol.23/5_808-841.pdf
Publication
Note
20210803

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...