In GE Financial Investments, the Upper Tribunal favoured the functional interpretation while the Court of Appeal favoured the territorial, writes Kyle Rainsford (Addleshaw Goddard).
If it looks like a resident and it is taxed like a resident is it a resident? The Court of Appeal in HMRC v GE Financial Investments Ltd [2024] EWCA Civ 797 says no overturning the judgment of the Upper Tribunal (UT) that I discussed this time last year (‘GE Financial treaty residence and the meaning of “business”’ (K Rainsford) Tax Journal 28 July 2023).
The taxpayer GE Financial Investments Ltd (GEFI) was a UK company. For US tax planning purposes (which were defeated by...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
In GE Financial Investments, the Upper Tribunal favoured the functional interpretation while the Court of Appeal favoured the territorial, writes Kyle Rainsford (Addleshaw Goddard).
If it looks like a resident and it is taxed like a resident is it a resident? The Court of Appeal in HMRC v GE Financial Investments Ltd [2024] EWCA Civ 797 says no overturning the judgment of the Upper Tribunal (UT) that I discussed this time last year (‘GE Financial treaty residence and the meaning of “business”’ (K Rainsford) Tax Journal 28 July 2023).
The taxpayer GE Financial Investments Ltd (GEFI) was a UK company. For US tax planning purposes (which were defeated by...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
