The Commissioners for HM Revenue and Customs v Investec Asset Finance Plc and Investec Bank Plc:[2018] UKUT 0069 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Arnold and Judge Hellier on 4 April 2018.
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Corporation tax 鈥� Purchase by traders of partnership interests and adherence to partnerships followed by realisation and distribution by partnerships of receivables 鈥� whether purchase price of partnership interests and contributions to capital of partnerships were capital or revenue expenditure 鈥� if revenue, whether incurred wholly and exclusively for purposes of traders鈥� trades 鈥� if revenue incurred wholly and exclusively, whether HMRC entitled to raise further issue not in closure notice 鈥� whether partnership profits distributed to traders subject to two tax computations.
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Published 4 April 2018