Irish Bank Resolution Corporation Ltd (in special liquidation) and Irish Nationwide Building Society v The Commissioners for HM Revenue and Customs: [2019] UKUT 0277 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Marcus Smith and Judge Herrington on 9 October 2019.

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 9 October 2019

• Category: Tax
• Release date: 9 October 2019

Read the full decision in Irish Bank Resolution Corporation Ltd (in special liquidation) and Irish Nationwide Building Society v The Commissioners for HM Revenue and Customs: [2019] UKUT 0277 (TCC).

CORPORATION TAX – UK branches of Irish banks – interest expense – whether deductible – attribution of notional capital – ICTA section 11AA(3)(b) – construction and application of UK – Ireland DTC.

Published 9 October 2019