08 February 2017

UT Decision: (1) Travel Document Service (2) Ladbroke Group International v HMRC

Corporation tax – tax avoidance scheme – use of total return swap over shares in subsidiary to create a deemed creditor relationship – value of shares depressed by novating liability for large loans to subsidiary – whether loan relationships had unallowable purpose – whether debits attributable to unallowable purpose.
Julian Ghosh QC & Elizabeth Wilson, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents.
To see the approved Decision, click here.