Explainaway Limited, Quartfed Limited and Parastream Limited v The Commissioners for HM Revenue and Customs: [2012] UKUT 362 (TCC)

Upper Tribunal Tax & Chancery decision of Mr Justice Newey and Judge Sinfield on 19 October 2012.

Read the full decision in (1) Explainaway Limited (2) Quartfed Limited (3) Parastream Limited v The Commissioners for HM Revenue and Customs: [2012] UKUT 362 (TCC).

CORPORATION TAX – scheme to avoid tax on chargeable gains – whether derivative transactions gave rise to chargeable gains and losses – whether loss arising on disposal of shares in group company was an allowable loss – ICTA, s 128, and TCGA, ss 2 and 143 – application of Ramsay principle.

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