High Court rules in favour of taxpayers in thin cap GLO case
November 19, 2009
The test claimants in the UK thin-capitalisation group litigation against HM Revenue & Customs have won their challenge in the High Court in London that the rules infringed the freedom of establishment article of the European Treaty.
The case relates to the tax treatment of interest paid by UK taxpayers for loans granted by a non-resident company belonging to the same group. The test claimants, which comprised IBM, Lafarge, Siemens, Standard Bank and Volvo, were represented by Dorsey & Whitney.
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