In Hargreaves Property Holdings Ltd v HMRC [2023] UKUT 120 (TCC) the Upper Tribunal (UT) dismissed the taxpayer’s appeal against the determination of the First-tier Tribunal (FTT) that UK income tax should have been deducted from interest payments on debt financing provided to the group. The FTT’s decision was reviewed in “Direct Tax Cases: Decisions from the UK Courts and Other International Cases”, Irish Tax Review, 35/1 (2022).
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