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United Kingdom Upper Tribunal (Tax and Chancery Chamber)


You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Irish Bank Resolution Corporation Ltd & Anor v Revenue and Customs (CORPORATION TAX - interest expense) [2019] UKUT 277 (TCC) (9 October 2019)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2019/277.html
Cite as: [2019] STI 1684, [2019] UKUT 277 (TCC), [2019] STC 2286, [2019] BTC 524, 22 ITL Rep 224

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Irish Bank Resolution Corporation Ltd (in special liquidation) and Irish Nationwide Building Society v Revenue and Customs: [2019] UKUT 277 (TCC) (9 October 2019)


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.

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URL: http://www.bailii.org/uk/cases/UKUT/TCC/2019/277.html