- FTT allows unilateral credit for US withholding tax when treaty relief did not apply (Aozora GMAC Investments v HMRC)
- What are the practical implications of this case?
- What was the background?
- What did the tribunal decide?
- Case details
Tax analysis: The First-tier Tax Tribunal (FTT) in Aozora GMAC Investments v HMRC allowed Aozora’s appeal. The relevant legislation at the time, section 793A(3) of the Income and Corporation Taxes Act 1988 (ICTA 1988) (now found in section 11(3) of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010)), did not prevent Aozora from being entitled in the UK to unilateral relief by way of credit for US withholding tax on interest.
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