Travel Document Service and Another v The Commissioners for HM Revenue and Customs: [2017] UKUT 0045 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Arnold and Judge Herrington on 7 February 2017.
Read the full decision in .
Corporation tax 鈥� tax avoidance scheme 鈥� use of total return swap over shares in subsidiary to create a deemed creditor relationship 鈥� value of shares depressed by novating liability for large loans to subsidiary 鈥� whether loan relationships had unallowable purpose 鈥� whether debits attributable to unallowable purpose.
Updates to this page
Published 21 February 2017