30 April 2020

Investec v HMRC; (Court of Appeal)

The Court of Appeal, inter alia, dismissed the appeal of the taxpayer companies against the decision of the Upper Tribunal that capital contributions by them to  partnerships, in which they were partners and which carried on separate finance leasing trades, were not wholly and exclusively for the purposes of their individual financial trades.

John Tallon QC and James Rivett QC, Counsel, (instructed by HMRC Solicitors Office) for HMRC.

The judgment can be viewed here.