The Court of Appeal (CoA) has dismissed the taxpayer’s appeal in Hargreaves Property Holdings Ltd v Revenue and Customs [2024] EWCA Civ 365opens in a new tab, concluding that the UK’s withholding tax (WHT) rules did apply to debt financing provided to the company by overseas lenders.
The decision provides a helpful overview of both the principles of purposive interpretation as applied to tax legislation and the concept of beneficial ownership/entitlement used in various places in the UK tax code.