Commissioners for His Majesty's Revenue and Customs v GE Financial Investments, [2024] EWCA Civ 797

Case tabs

Summaries

Summary Under

deemed US residence of UK corporation under US stapling rules did not cause residence for Treaty purposes

A US company (“GEFI Inc.”) and UK company (“GEFI”) in the GE group formed a Delaware LP (“LP”) with GEFI Inc. as the 1% general...

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

Summary Under

passive holding of intercompany loans was not carrying on business for purposes of PE definition in UK-US Treaty

A US company (“GEFI Inc.”) and UK company (“GEFI”) in the GE group formed a Delaware LP (“LP”) with GEFI Inc. as the 1% general...

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