25 February 2015
UT Decision: Spritebeam, Prowting & HMRC v HMRC & Versteegh
CORPORATION TAX — company lends money to another group company on terms that shares are paid to a different group company — is the value of the shares income of the lender under the loan relationship rules? — no, but only because of the effect of s. 80(5) of the Finance Act 1996 — is the value of the shares income of the share recipient? — yes — appeals dismissed.
Kevin Prosser QC & James Henderson, instructed by PWC Legal LLP, acted for the first two Appellants and the second Respondent.
Julian Ghosh QC & Barbara Belgrano acted for HMRC.
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