OrbitaxFCE Bank case – Court of Appeal holds UK's former group relief rules in breach of treaty non-discrimination article
|Treaty Development|United Kingdom
On 17 October 2012, the Court of Appeal dismissed HMRC's appeal in CRC v FCE Bank Plc.
(a) Facts and legal background
HMRC had appealed against a decision from the Upper Tribunal that the UK's pre-2000 group relief rules breached the non-discrimination article in the United Kingdom - United States Income Tax Treaty (1975).
The Upper Tribunal's decision itself upheld that of the Fir…
