Macklin v HMRC[2013] UKFTT 554 (TC)

10th October 2013

Whether the World Bank's retirement scheme was ‘established in the US’ for the purposes of the UK-US tax treaty, articles 3(1)(o) and 17(1)(b), so that UK resident former employees are eligible for relief from UK income tax. The appeal involves interpretation of the treaty establishing the World Bank, its relationship with US law, and interpretation of the UK-US tax treaty. One of very few cases around the world address taxation and International organisations. Key issues include admissibility of evidence on treaty meaning, expert evidence on foreign tax law, principles of tax treaty interpretation.


Appeal to Upper Tribunal to be heard.


Counsel for Appellant: Jonathan Schwarz


To read the decision click here

Associated Members

Jonathan S. Schwarz