Ardmore Construction Ltd v Revenue and Customs Commissioners

Citation:

16 ITLR 992 and [2014] UKFTT 453 (TC)

Judgment Date:

21 May 2014

James Kessler QC and Amanda Hardy acted for the appellant.

Income – United Kingdom – Source of income – Interest payments on loan – Loan by Gibraltar trusts to associated UK company – Loan financed by subscription of shares by taxpayer in overseas company which lent money to trusts – Whether interest payments arose in UK – Whether place in which loan made determinative – What factors relevant.