23 October 2014

FTT Decision: Biffa (Jersey) Ltd v HMRC

CORPORATION TAX – deemed loan transactions under section 730A ICTA 1988 – whether effect of section 195 FA 2003 that acquisition of own shares disregarded for purposes of section 730A – no – alternatively whether section 27 F(No 2)A 2005 applies in relation to £214,108,391 paid by BCHL to BJL on 25 September 2008 – no – appeal dismissed

David Yates acted for HMRC.

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