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Claims for tax relief by US multinational groups with UK joint venture interests have been given a boost by the UK Court of Appeal's decision in FCE Bank Plc
The recent decision of the UK High Court, overturning a decision of the Special Commissioners (the former first-tier tax appeals court in the UK), in Bayfine UK v HMRC 2010 EWHC 609 provides an interesting insight into the interpretation of the UKUS double tax treaty in the context of "hybrid" entities, ie UK tax resident companies that are disregarded for US tax purposes
