HMRC has welcomed the Court of Appeal's judgment, released on Friday, in Test Claimants in the Thin Cap Group Litigation v HMRC [2011] EWCA Civ 127.
HMRC told Tax Journal that the decision confirmed that ‘the UK's thin capitalisation and transfer pricing rules that are based on the internationally accepted arm's length principle are fully consistent with EU law’.
The Court held by a majority that the UK’s thin capitalisation legislation complied with the ECJ’s 2007 judgment in the thin cap group litigation order ‘and thus was acceptable,’ Deloitte said in a business tax briefing.
HMRC has welcomed the Court of Appeal's judgment, released on Friday, in Test Claimants in the Thin Cap Group Litigation v HMRC [2011] EWCA Civ 127.
HMRC told Tax Journal that the decision confirmed that ‘the UK's thin capitalisation and transfer pricing rules that are based on the internationally accepted arm's length principle are fully consistent with EU law’.
The Court held by a majority that the UK’s thin capitalisation legislation complied with the ECJ’s 2007 judgment in the thin cap group litigation order ‘and thus was acceptable,’ Deloitte said in a business tax briefing.
