UK

High Court decides on non-discrimination relief under Swiss tax treaty

On 7 February 2006, the High Court gave judgment in the case of UBS AG v. Revenue and Customs [2006] EWHC 117 (Ch) concerning the claim of the UK branch of a Swiss resident company under Sec. 243 of the Income and Corporation Taxes Act 1988 (ICTA) to payment of a sum equal to the tax credit on UK dividends received by the branch. The facts are as stated in the report of the decision of the Special C…