SCIT DEBT CONTRACTS – whether self-cancelling contracts can be looked at together – yes but s 165 FA 1994 still not applicable – in the light of Tower MCashback can the Revenue raise s 167 FA 1994 having made their amendment to the self-assessment under s 165 – yes – whether s 167 applies – no.
DOUBLE TAXATION RELIEF – US ignoring UK subsidiary with unlimited liability for US tax purposes and taxing the parent on the subsidiary’s profit – whether unilateral relief for US tax paid by the parent – no – whether treaty relief under US-UK tax treaty (1975) – no – whether, had relief been available, certain steps would be reasonable to take to reduce US tax – no – appeal dismissed.
Citations:
[2008] UKSPC SPC00719
Links:
Statutes:
Income Tax
Updated: 21 July 2022; Ref: scu.278756