UK Appeal Court Upholds Irish Company’s Tax Treaty Refund Claims

April 21, 2026, 3:59 PM UTC

An Irish investment company is entitled to an £18.1 million ($24.4 million) tax refund on debt interest arising from the closure of Lehman Brothers, a UK court has ruled.

Dublin-based firm Burlington Loan Management’s acquisition of a debt claim didn’t constitute treaty abuse even if its purpose was to get tax exemptions provided by the treaty, the Court of Appeal said in a decision Monday, dismissing His Majesty’s Revenue and Customs’ appeal.

The dispute related to tax treatment of £90.7 million in post-administration interest from Lehman Brothers International (Europe). Burlington Loan Management had acquired the debt claim from Saad ...

Learn more about Bloomberg Tax or Log In to keep reading:

See Breaking News in Context

From research to software to news, find what you need to stay ahead.

Already a subscriber?

Log in to keep reading or access research tools and resources.