The Resource Irish Bank Resolution Corporation Limited (In Special Liquidation) v The Commissioners for Her Majesty's Revenue and Customs : is it permissible to use a hypothetical balance sheet in computing branch profits?

Irish Bank Resolution Corporation Limited (In Special Liquidation) v The Commissioners for Her Majesty's Revenue and Customs : is it permissible to use a hypothetical balance sheet in computing branch profits?

Label
Irish Bank Resolution Corporation Limited (In Special Liquidation) v The Commissioners for Her Majesty's Revenue and Customs : is it permissible to use a hypothetical balance sheet in computing branch profits?
Title
Irish Bank Resolution Corporation Limited (In Special Liquidation) v The Commissioners for Her Majesty's Revenue and Customs : is it permissible to use a hypothetical balance sheet in computing branch profits?
Creator
Subject
Language
eng
Summary
This case note comments on Irish Bank Resolution Corp Ltd (In Special Liquidation) v Revenue and Customs Commissioners (CA) on the permissibility under a double taxation treaty of assuming that a branch of a foreign bank had an "arms' length" capital structure for the purpose of calculating its chargeable profits. It considers the constitutional position of such treaties, the relevant OECD instruments, foreign cases and the relevance of intra-group relationships
Citation source
In: British tax review. - London. - (2021), no. 1 ; p. 44-51
http://library.link/vocab/creatorName
Peacock, J.D
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • corporate income tax
  • case law
  • transfer pricing
  • arm's length principle
  • tax treaty
  • allocation of profits
  • PE
  • branch
  • foreign bank
  • OECD Model
  • OECD Model Commentaries
  • constitutional law
Label
Irish Bank Resolution Corporation Limited (In Special Liquidation) v The Commissioners for Her Majesty's Revenue and Customs : is it permissible to use a hypothetical balance sheet in computing branch profits?
Instantiates
Publication
Label
Irish Bank Resolution Corporation Limited (In Special Liquidation) v The Commissioners for Her Majesty's Revenue and Customs : is it permissible to use a hypothetical balance sheet in computing branch profits?
Publication

Library Locations

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