TREATMENT OF INTEREST IN EUROCEANICA

摘要

In Euroceanica (UK) Ltd v Revenue & Customs [2013] UKFTT313(TC), at issue was an appeal against a closure notice and concerns about the tax treatment of interest income arising to the Appellant (Euroceanica) for the accounting periods ending 31 December 2006, 2007, 2008 and 2009 amounting to $4,094,648 (£2.693m).The interest in question arose from cash collateral deposited by Euroceanica with two Italian banks as part of its loan arrangements with those banks for the financing of its shipping fleet. The question for the FTT was whether that interest fell, for UK tax purposes, to be treated as within the favourable tonnage tax regime, or within the normal, and less favourable, corporation tax regime in the UK.