Denial Of Irish Banks' Tax Deductions Upheld By UK Court

Law360 (October 9, 2019, 8:42 PM EDT) -- Britain's tax authority was right to disallow deductions claimed against interest expenses paid by two Irish banks' U.K. branches despite terms of a bilateral tax treaty, a court in London ruled Wednesday.

The Upper Tribunal Tax and Chancery Chamber, affirming a September 2017 decision by the First-Tier Tribunal, found that the delineation of taxing authority outlined in Britain's income tax statute isn't precluded by terms of the 1976 Irish-U.K. treaty on double taxation.

That, the Upper Tribunal said, means Ireland-based Irish Bank Resolution Corp. Ltd. — now in liquidation — and the Irish Nationwide Building Society, which did business as permanent...

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