The Resource Perrin v Revenue and Customs Commissioners : [2014] UKFTT 223 (TC)

Perrin v Revenue and Customs Commissioners : [2014] UKFTT 223 (TC)

Label
Perrin v Revenue and Customs Commissioners : [2014] UKFTT 223 (TC)
Title
Perrin v Revenue and Customs Commissioners : [2014] UKFTT 223 (TC)
Contributor
Subject
Language
eng
Summary
Judgment by the First-tier Tribunal (tax), judgment date 26 February 2014. The taxpayer was a resident in the UK and was the main beneficiary of an Employer Funded Retirement Benefit Scheme funded by a UK company which he controlled. The trustee of the scheme was an Isle of Man trustee company. The trustee made substantial loans to the taxpayer which were due to be repaid in five years. The loan contracts were stated to be subject to the law of the Isle of Man and any disputes were to be resolved in the courts of the Isle of Man. The taxpayer drew down the loans and applied them mostly to purposes in England but left a sum in an Isle of Man bank account which was sufficient to pay the interest owing on the loans for the first two years or so. He made payments of interest from that account into the scheme account, also in the Isle of Man. The Revenue and Customs Commissioners in the UK considered that the interest payments were income that arose in the UK and therefore liable to UK tax. The taxpayer objected that the interest payments arose in the Isle of Man. This case looked into questions like whether the interest arose in the UK, whether the situs of the debt was in England, and which factors affected determination of the source of the interest
Citation source
In: International tax law reports. - London. - Vol. 16 (2014),
Geographic coverage
Europe
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • tax treaty
  • debt
  • interest
  • situs rule
  • source of income
  • residence
Label
Perrin v Revenue and Customs Commissioners : [2014] UKFTT 223 (TC)
Instantiates
Publication
Label
Perrin v Revenue and Customs Commissioners : [2014] UKFTT 223 (TC)
Publication

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