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Separate enterprise principle does not require a look-through to partnership assets (Bloomberg v HMRC)

Separate enterprise principle does not require a look-through to partnership assets (Bloomberg v HMRC)
Published on: 20 April 2018
Published by: LexisPSL
  • Separate enterprise principle does not require a look-through to partnership assets (Bloomberg v HMRC)
  • What are the practical implications of this case?
  • What was the background?
  • What did the court decide?
  • Extent of the principle that a PE should be treated as a separate and distinct entity
  • Case details

Article summary

Tax analysis: The First-tier Tax Tribunal upheld HMRC’s decision to deny an election for amortisation deductions on intangible fixed assets for the UK permanent establishments (PEs) of non-UK resident companies that had acquired additional partnership interests. The FTT found that the separate enterprise principle in Article 7 of the UK-US Double Tax Treaty DTT) did not require (or enable) looking through the partnership to the underlying intangible fixed assets. or take a trial to read the full analysis.

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