Aozora Gmac Investments Limited v Revenue and Customs (Corporation Tax – Interest Paid By Us Subsidiary To UK Parent Company): FTTTx 12 Apr 2021

CORPORATION TAX – interest paid by US subsidiary to UK parent company – interest subject to deduction of US withholding tax – no entitlement to benefit of relief under US/UK tax treaty – is unilateral credit for US withholding tax available – s793A(3) ICTA 1988
[2021] UKFTT 99 (TC)
Bailii
England and Wales

Updated: 14 October 2021; Ref: scu.663674