INCOME TAX – whether FTT correct that obligation to withhold tax under ITA 2007, s 874 arose
on interest payments – yes – appeal dismissed
Heard on: 8 March 2023
Judgment date: 26 May 2023
Before
MRS JUSTICE BACON
JUDGE SWAMI RAGHAVAN
Between
HARGREAVES PROPERTY HOLDINGS LIMITED
Appellant
and
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant: Patrick Way KC and Dilpreet K. Dhanoa, counsel, instructed by BDO LLP
For the Respondents: Richard Vallat KC and Calypso Blaj, counsel, instructed by the General
Counsel and Solicitor to His Majesty’s Revenue and Customs
