James Kessler QC and Amanda Hardy (instructed by BDO Stoy Hayward LLP) for Ardmore.
Interest – Source of interest – Interest arising in the United Kingdom – Interest payments made by United Kingdom company to Gibraltar-based trusts – Whether interest ‘arising in the United Kingdom’ – Income Tax Act 2007, s 874.
Tribunal – Procedure – Precedent – Previous unpublished and confidential decision – Whether HMRC permitted to cite decision after providing taxpayer with copy.