THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS v BURLINGTON LOAN MANAGEMENT DAC [2024] UKUT 00152 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Richards and Judge Andrew Scott on 31st May 2024
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INCOME TAX – meaning of Article 12(5) of the UK-Ireland double tax convention – whether the FTT erred in law in considering whether persons concerned in assignment of a debt claim had main purpose of taking advantage of Article 12(1) of the UK-Ireland double tax convention – no– appeal dismissed