Shop Direct Group, Shop Direct Home Shopping Limited, Reality Group Limited and Littlewoods Retail Limited v The Commissioners for HM Revenue and Customs: [2013] UKUT 0189 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Asplin on 19 April 2013.
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Corporation Tax: Effect of receipt by trader or successor to trade of sums in respect of VAT repaid under s80 VATA to representative member of VAT group plus interest paid under s78 VATA. Question of beneficial ownership of sums received and whether “arising from the trade”. Application of sections 103 and 106 ICTA 1988. Whether interest payments could be characterised as arising under a “loan relationship” and amounted to a “money debt” for purposes of section 100 FA 1996.”
Published 1 December 2016