Search Results for: UK-Switzerland Double Taxation Convention of 8 December 1977

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UBS Ag v HM Revenue and Customs: ChD 7 Feb 2006

The bank, based in Switzerland sought tax credits for the activities of its London branch. Held: Although the argument under s243 directly failed, the claim under section 788(3) had to succeed. The Swiss company was entitled to the same tax credits as would have been available to a UK corporation. Judges: Etherton J Citations: Times … Continue reading UBS Ag v HM Revenue and Customs: ChD 7 Feb 2006

HM Revenue and Customs v UBS Ag: CA 21 Feb 2007

The court considered the treatment of losses in a London branch of the non-resident Bank. Had the company been resident it could have set off the losses. It claimed that the refusal was an unlawful discrimination. Judges: Sedley, Arden, Moses LJJ Citations: [2007] EWCA Civ 119 Links: Bailii Statutes: UK-Switzerland Double Taxation Convention of 8 … Continue reading HM Revenue and Customs v UBS Ag: CA 21 Feb 2007