THE COMMISSIONERS FOR HIS MAJESTY鈥橲 REVENUE AND CUSTOMS v RAJ SEHGAL (1) SANJEEV MEHAN (2) [2024] UKUT 00074 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Adam Johnson and Judge Kevin Poole on 25th March 2024
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Remittance of foreign gains 鈥� s 809L ITA 2007 鈥� indemnity liability waived and UK inter-company debt not pursued pursuant to payment by non-UK third party overseas in separate transaction financed by taxpayers using proceeds of offshore chargeable gains 鈥� whether service provided or money used in the UK 鈥� whether money or consideration for service were or were derived from the gain 鈥� whether money used in UK was the gain 鈥� whether money that was or was derived from chargeable gains was used outside the UK in respect of a relevant debt
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Published 25 March 2024