Burlington Loan Management v HMRC [2026] EWCA Civ 461: Court of Appeal Draws the Line on Treaty Anti-Abuse – CFO Action Points
The Court of Appeal in Burlington Loan Management v HMRC [2026] EWCA Civ 461 has clarified when treaty anti-abuse rules actually apply. HMRC lost. Here is what CFOs with cross-border structures, intragroup debt, and withholding tax positions need to do now.










