Emily Szasz and Charlotte Anderson (Freshfields Bruckhaus Deringer) examine the FTT decision on the interaction between domestic appeals and MAPs which are provided for in double tax treaties.
In Glencore Energy Ltd and another v HMRC [2019] UKFTT 438 (TC) the First-tier Tribunal (FTT) has granted a stay application requested by two Glencore entities (one UK resident and one Swiss resident) which are appealing various corporation tax and diverted profits tax (DPT) assessments. That may not sound particularly newsworthy but the decision offers some important insights into the interaction between domestic appeals and mutual agreement procedures (MAPs) which are provided for in double tax treaties.
Background to the appeals
Some may recall that the arrangements between these two companies formed part of the background to an unsuccessful 2017 judicial review application in respect of a DPT charge levied by HMRC (R (on the application of Glencore...
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Emily Szasz and Charlotte Anderson (Freshfields Bruckhaus Deringer) examine the FTT decision on the interaction between domestic appeals and MAPs which are provided for in double tax treaties.
In Glencore Energy Ltd and another v HMRC [2019] UKFTT 438 (TC) the First-tier Tribunal (FTT) has granted a stay application requested by two Glencore entities (one UK resident and one Swiss resident) which are appealing various corporation tax and diverted profits tax (DPT) assessments. That may not sound particularly newsworthy but the decision offers some important insights into the interaction between domestic appeals and mutual agreement procedures (MAPs) which are provided for in double tax treaties.
Background to the appeals
Some may recall that the arrangements between these two companies formed part of the background to an unsuccessful 2017 judicial review application in respect of a DPT charge levied by HMRC (R (on the application of Glencore...
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:
