CORPORATION TAX — avoidance scheme — transfer of contingent,
unrecognised, claim against third party to subsidiary in exchange for shares —
subsidiary recognising value of asset despite contingency but parent not recognising
shares — whether accounting GAAP-compliant — yes — loan relationship rules —
whether FA 1996 s 84(1) engaged — yes — recognised value of asset to be brought
into account as credit in parent’s corporation tax computation —appeal dismissed
PROCEDURE — opening of enquiry — whether error in identification of
accounting period invalidates enquiry — no, if intention clear.