The Court of Appeal has confirmed in Burlington Loan Management DAC v HMRC that “obtaining the benefit of” a tax treaty is not the same as “taking advantage of” it. The treaty anti-abuse rule will only apply where the taxpayer seeks to obtain that benefit in a way that is
William Gomes
William Gomes is a Tax associate and a member of the Private Funds Group.
Will’s primary focus is tax planning for a broad range of private fund clients. He advises private equity fund managers on tax aspects of fundraising and internal organisational matters, as well as their investment activities. Another significant aspect of Will’s practice involves advising various types of institutional investors on their investments in global private investment funds.
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