The Resource Bayfine UK v Revenue and Customs Commissioners : [2010] EWHC 609 (Ch)

Bayfine UK v Revenue and Customs Commissioners : [2010] EWHC 609 (Ch)

Label
Bayfine UK v Revenue and Customs Commissioners : [2010] EWHC 609 (Ch)
Title
Bayfine UK v Revenue and Customs Commissioners : [2010] EWHC 609 (Ch)
Contributor
Subject
Language
eng
Summary
Judgment by the Chancery Division dated 23 March 2010. This case involved a contrived tax avoidance scheme designed to create an allowable loss plus a foreign tax credit. Two equal and opposite contracts ensured that, whichever way an interest rate moved, there would be a loss for one member of a group of companies and a gain for another. The Revenue rejected the claim for double taxation relief, and the Special Commissioners dismissed the appeal. Upon appeal to the Chancery Division, it was held that this was a classic case of a profit arising abroad on the part of a company that was resident in the UK, and that the company was entitled to unilateral relief
Citation source
In: International tax law reports. - London. - Vol. 12 (2010),
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • double taxation
  • double taxation relief
  • unilateral relief
  • tax treaty
Label
Bayfine UK v Revenue and Customs Commissioners : [2010] EWHC 609 (Ch)
Instantiates
Publication
Label
Bayfine UK v Revenue and Customs Commissioners : [2010] EWHC 609 (Ch)
Publication

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