UK Appeals Court Upholds Deduction Denials To Irish Banks

Law360 (August 28, 2020, 7:36 PM EDT) -- A U.K. appellate court Friday found HM Revenue & Customs was correct to deny deductions claimed against interest expenses paid by British branches of two Irish banks despite the terms of a bilateral tax treaty.

The civil division of the U.K. Court of Appeal, affirming the rulings of two lower courts, held that Irish Bank Resolution Corp. Ltd. — now in liquidation — and the Irish Nationwide Building Society weren't eligible for interest expense deductions. Both banks, which did business as permanent establishments of different banks registered in Ireland, had claimed that the double-tax treaty between the U.K. and Ireland entitled...

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