Shinelock Limited v The Commissioners for HM Revenue and Customs [2023] UKUT 00107 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Thomas Scott and Judge Asley Greenbank on 15 May 2023
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CORPORATION TAX 鈥� chargeable gain on disposal of property 鈥� whether payment made by disposing company to controlling party was a deductible loan relationship debit 鈥� whether such payment was a distribution 鈥� whether FTT decided issues on basis of arguments which had not been pleaded 鈥� raising 鈥渘ew鈥� issues in an FTT hearing 鈥� appeal dismissed
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Published 17 May 2023