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CORPORATION TAX — company lends money to another group company on terms that
shares are paid to a different group company — is the value of the shares income of
the lender under the loan relationship rules? — no, but only because of the effect of
s. 80(5) of the Finance Act 1996 — is the value of the shares income of the share
recipient? — yes — appeals dismissed.
Published 1 December 2016