HM Revenue and Customs (appellant) v GE Financial Investments (respondent)
Tuesday 2 – Wednesday 3 July 2024
By appellant’s notice filed on 12 October 2023, the appellant, HMRC, appeals, with the permission of the Upper Tribunal (Tax and Chancery Chamber), their decision of 29 June 2023, whereby they allowed the appeal of the taxpayer GE Financial Investments.
The appeal concerns the interpretation of the UK/USA double tax convention and its application to the respondent, GE Financial Investments (“GEFI”) for its accounting periods ending 31 December 2003 to 31 December 2008.
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Day 1
Day 2