In Hargreaves Property Holdings Ltd v Revenue and Customs [2024] EWCA Civ. 365 the England and Wales Court of Appeal rejected the taxpayer’s appeal, determining that the UK’s withholding tax (WHT) rules applied to debt financing provided to the company. The Upper Tribunal’s decision was reviewed in “Direct Tax Cases: Decisions from the UK and European Courts”, Irish Tax Review, 36/3 (2023).
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