Interpreting double tax treaties:Vietjet Aviation Joint Stock Company v FW Aviation (Holdings) 1 Ltd [2025] EWCA Civ 783 (24 June) concerned a commercial dispute between two parties relating to the financing of the acquisition of four jet aircraft. One of the disputed terms in the contract made reference to the UK-Japan double tax treaty. Paragraphs [68]–[116] contain a detailed analysis of the way in which double tax treaties should be interpreted include a discussion of whether carrying on an investment business and carrying on a trade are always mutually exclusive concepts. The judge also considered whether the anti-avoidance provisions in the treaty could have been invoked.
Multiple dwellings relief:S Smith and another v HMRC [2025] UKFTT 752 (TC) (19 June) is another decision on multiple dwellings relief for SDLT. Such decisions are highly fact-dependent. The FTT here was clear that although particular...
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Interpreting double tax treaties:Vietjet Aviation Joint Stock Company v FW Aviation (Holdings) 1 Ltd [2025] EWCA Civ 783 (24 June) concerned a commercial dispute between two parties relating to the financing of the acquisition of four jet aircraft. One of the disputed terms in the contract made reference to the UK-Japan double tax treaty. Paragraphs [68]–[116] contain a detailed analysis of the way in which double tax treaties should be interpreted include a discussion of whether carrying on an investment business and carrying on a trade are always mutually exclusive concepts. The judge also considered whether the anti-avoidance provisions in the treaty could have been invoked.
Multiple dwellings relief:S Smith and another v HMRC [2025] UKFTT 752 (TC) (19 June) is another decision on multiple dwellings relief for SDLT. Such decisions are highly fact-dependent. The FTT here was clear that although particular...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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