(1) SCOTTISHPOWER (SCPL) LIMITED (2) SCOTTISHPOWER RENEWABLES (UK) LIMITED (3) SCOTTISHPOWER (DCL) LIMITED (4) SCOTTISHPOWER ENERGY RETAIL LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Upper Tribunal Tax and Chancery decision of Mr Justice Miles and Upper Tribunal Judge Swami Raghavan on 05 September 2023
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CORPORATION TAX – whether FTT erred in finding payments pursuant to settlement agreements with regulators were non-deductible – no – taxpayers’ appeals dismissed. Whether FTT erred in treating an element of payment which it consider deductible when that payment was part of a package of payments having a penal character – yes – HMRC’s appeal allowed
Published 5 September 2023