Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152

Case tabs

Summaries

Summary Under

Irishco’s purchasing a UK interest claim from Caymansco at a tax arbitrage price did not have Treaty-reduction as a main purpose

BLM was a substantial Irish-resident investment company, which started acquiring proved claims in the administration of Lehman Brothers...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases

Summary Under

accessing Irish-UK treaty dividend-withholding reduction was not abusive given that not a treaty-shopping or conduit transaction

BLM was a substantial Irish-resident investment company, which had been acquiring proved claims in the administration of Lehman Brothers...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.