HM Revenue & Customs (appellant) v Burlington Loan Management DAC (respondent)
Wednesday 10 – Thursday 11 December 2025
By Appellant’s Notice filed on 12 August 2024, the Appellant (Appellant below) HM Revenue and Customs, appeal the decision of the Upper Tribunal (Tax and Chancery Chamber), judgment being delivered on 31 May 2024.
This appeal concerns withholding tax on statutory interest earned on debt held in the Lehmans Europe administration. The issue was whether the parties to the debt assignment had a main purpose to “take advantage” of the residence provision (Article 12) in the UK-Irish Double Tax Treaty. The First Tier Tribunal allowed Burlington’s appeal, finding that the parties did not have such a purpose.
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Day 1
Day 2