UK Court of Appeal Upholds Treaty Relief in Win for Secondary Market Participants
UK Court of Appeal Upholds Treaty Relief in Win for Secondary Market Participants
In welcome news for secondary debt markets, the UK Court of Appeal upheld decisions in the lower tribunals in favour of the taxpayer that the “principal purpose test” (PPT) in the UK/Irish double tax treaty (DTT) did not apply to deny relief for UK withholding tax (WHT).... By: Paul Hastings LLP