03 March 2015
FTT Decision: Gemsupa Ltd & CPG Wilmslow v HMRC
CORPORATION TAX – chargeable gains – group relief – sections 170, 171 TCGA 1992 – tax avoidance scheme – Ramsay principle – purposive construction of the group relief provisions – whether the transactions fell within the group relief provisions – appeal allowed.
Julian Ghosh QC & Jonathan Bremner, instructed by Mr William Marshall Smith (in-house solicitor) acted for the Appellant.
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