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Court of Appeal Delivers Clarity: Burlington Ruling Sets the Bar for Purpose Tests and Treaty Benefits in International Tax

UnknownApr 24, 2026(9 days ago)

Court of Appeal Delivers Clarity: Burlington Ruling Sets the Bar for Purpose Tests and Treaty Benefits in International Tax

The much-anticipated Court of Appeal judgment in HMRC v. Burlington Loan Management DAC [2026] provides some welcome clarity and reassurance to taxpayers (and their advisers) grappling with the application of purpose tests in an international tax context.... By: Ropes & Gray LLP

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