Ardmore Construction Ltd v Revenue and Customs Commissioners

Citation:

[2014] SFTD 1077 and [2014] UKFTT 453 (TC)

Judgment Date:

21 May 2014

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Tribunal – Procedure – Precedent – Previous unpublished and confidential decision – Whether HMRC permitted to cite decision after providing taxpayer with copy.