Site icon swarb.co.uk

Bloomberg Inc (Uk Permanent Establishment) and Another v Revenue and Customs (Income Tax/Corporation Tax : Double Taxation): FTTTx 16 Apr 2018

INCOME TAX – corporation tax – permanent establishments in UK – applicability of intangible fixed assets election to transaction – election refused by HMRC – whether application of separate and distinct principle under UK/US Double Taxation Convention meant that transaction to be regarded as transfer of assets as appellants contended rather than sale of partnership units as HMRC contended – HMRC correct to refuse election – appeal dismissed

Citations:

[2018] UKFTT 205 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 14 April 2022; Ref: scu.609256

Exit mobile version