(1) Ardmore Construction Limited (2) Andrew Colin Perrin v The Commissioners for HM Revenue and Customs: [2015] UKUT 0633 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Morgan and Judge Berner on 20 November 2015.
Read the full decision in .
INCOME TAX 鈥� deduction of tax at source 鈥� whether 鈥渋nterest arising in the United Kingdom鈥� 鈥� ITA 2007, s 874 鈥� source of interest - test to be applied 鈥� whether a multi-factorial test, a test of nationality of the loan document or a place of credit test 鈥� National Bank of Greece considered 鈥� appeals dismissed.
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Published 1 December 2016