Spritebeam Limited and Others v The Commissioners for HM Revenue and Customs and Versteegh Limited: [2015] UKUT 0075 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Proudman and Judge Bishopp on 25 February 2015.
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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