Court of Appeal rules on anti-abuse provisions in the UK: Japan Double Tax Treaty

As part of a wider commercial dispute relating to aircraft leases and Japanese investor financing, the Court of Appeal has provided useful guidance on the application of the anti-abuse provisions in the UK: Japan Double Tax Treaty and, in doing so, rejected Viet Jet’s case that a particular contractual status could amount to improperly “taking advantage” of the Treaty – see the Judgement here.  Jonathan Peacock KC, Sarah Black and Susanna Breslin acted for FWA, along with Richard Lissack KC, Tom Smith KC, Orestis Sherman and Robin Lööf.