The Union Castle Mail Steamship Company Ltd and The Commissioners for HM Revenue and Customs: [2018] UKUT 0316 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Fancourt and Judge Berner on 2 October 2018.
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CORPORATION TAX 鈥� derivative contracts 鈥� issue of bonus A Shares carrying a right to a dividend transferring 95% of economic benefit of financial options 鈥� derecognition of financial asset (IAS 39) 鈥� whether the accounting debit consequent upon derecognition fairly represents for the accounting period in question losses which arise to the company from its derivative contracts 鈥� FA 2002, Sch 26 鈥� whether transfer pricing provisions were applicable 鈥� ICTA, Sch 28A; FA 2002, Sch 26, para 31A 鈥� whether requirements of FA 2002, para 15 must be met in a case where para 25A applies.
Updates to this page
Published 2 October 2018