Vietjet Aviation JSC v FW Aviation (Holdings) Limited , [2025] EWCA Civ 783 -- attach -- Article 11
exclusion in Japan-UK treaty for “taking advantage” of the interest exemption applied only where doing so was abusive
Article 11
Revenue and Customs v Burlington Loan Management DAC , [2026] EWCA Civ 461 -- attach -- Article 11
“one of the main purposes” test in Art. 12(5) of UK-Ireland treaty was not engaged by purchasing interest coupon from a non-treaty vendor at a treaty-enhanced price
Aiken Industries Inc v Commissioner of Internal Revenues, (1971) 56 TC 925 -- attach -- Article 11
treaty exemption did not apply to interest received which was required to be on-paid
15 May 2019 IFA Roundtable Q. 3, 2019-0798741C6 - Participating Debt Interest & US Treaty -- attach -- Article 11
contingent interest under Art. XI(6)(b) of the US Treaty does not taint contemporaneous fixed interest
2017 Ruling 2017-0712731R3 - Amount of withholding tax under paragraph 212(1)(b) -- attach -- Article 11
CRA treats non-resident LPs as conduits for purposes of Treaty interest withholding relief
7 September 2016 External T.I. 2014-0563781E5 - Articles 10 and 11 of Canada-UK Treaty -- attach -- Article 11
limited partners of an LP can deal at arm’s length with a Canadian subsidiary of the LP
Ian Bradley, Denny Kwan, Dian Wang, "Is The Back-to-Back Withholding Tax Regime an Effective Anti-Treaty-shopping Measure?", Canadian Tax Journal, (2016) 64:4, 833-58 -- attach -- Article 11
4 September 1990 Memorandum (Tax Window, Prelim. No. 1, ¶1013) -- attach -- Article 11
Richard Collier, "Clarity, Opacity and Beneficial Ownership", British Tax Review, 2011, No. 6, p. 684: review of history of OECD commentaries on beneficial ownership concept and review of practices of tax authorities who use an economics-based interpretation. -- attach -- Article 11
5 February 2002 Internal T.I. 2000-0058637 - Interest Paid to Non-Resident -- attach -- Article 11
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