Irish Bank Resolution Corporation Ltd v Revenue and Customs, [2020] EWCA Civ 1128

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Summaries

Summary Under

interest expenses of PE could be reduced if it had insufficient free capital compared to the arm’s length standard

The Irish taxpayers, which carried on a UK branch banking business or a business of financing UK house purchases, were required to determine their...

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Summary Under

subsequently-added material in OECD Commentaries could be reviewed if they were not inconsistent with contemporaneous commentaries

HMRC increased the UK branch profits of the Irish taxpayers’ branch banking, or home mortgages, businesses by attributing to their UK permanent...

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