Irish Bank Resolution Corporation Ltd (in special liquidation) and Irish Nationwide Building Society v The Commissioners for HM Revenue and Customs: [2019] UKUT 0277 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Marcus Smith and Judge Herrington on 9 October 2019.
Read the full decision in .
CORPORATION TAX 鈥� UK branches of Irish banks 鈥� interest expense 鈥� whether deductible 鈥� attribution of notional capital 鈥� ICTA section 11AA(3)(b) 鈥� construction and application of UK 鈥� Ireland DTC.