[2026] UKUT 00090 (TCC) UK Care No.1 Limited v HMRC
Upper Tribunal Tax and Chancery decision of Judge Cannan and Judge Dean on 24 February 2026.
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Corporation Tax – loan relationships – section 327 Corporation Tax Act 2009 – disallowance of imported losses – non-resident company becoming UK resident prior to early redemption of loan notes – whether “loss” for the purposes of section 327 includes expenses incurred for the purposes of a loan relationship – whether sums paid on early redemption were expenses – whether a loss arising in connection with the loan relationship was referable to the pre-migration period
Updates to this page
Published 24 February 2026