United Kingdom on Withholding Tax

Welcome to the latest edition of our UK tax outlook designed to offer legal and practical insights into UK tax developments that have cross-border interest and relevance for your clients.

In HMRC v Burlington Loan Management DAC, the Upper Tribunal upheld that the anti-abuse provision in the UK/Ireland double tax treaty didn't apply, allowing Burlington to claim tax relief. The case underscores careful consideration of double tax treaties in structuring transactions.

The June UK Tax Round Up highlighted Court of Appeal's denial of interest deductions in JTI Acquisitions, Upper Tribunal's rejection of treaty abuse claims in Burlington Loan Management, and overturning of IR35 decision in Basic Broadcasting Ltd