SWISS CENTRE LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2026] UKUT 00227 (TCC)
Upper Tribunal Tax and Chancery decision of MR JUSTICE HUDDLESTON and JUDGE VINESH MANDALIA on 22 June 2026
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- Swiss Centre Ltd (“SCL” or “the appellant”) appeals against a decision of the First-tier Tribunal (Tax Chamber) (‘the FtT’ or ‘Tribunal’) released on 22 May 2023 under neutral citation [2023] UKFTT 449 (TC) (“the Decision”). The central issue in the appeal before the FtT was whether SCL is entitled to deduct an amount of approximately £33.5 million (the “Disputed Sum”) in calculating its profits for corporation tax purposes for the accounting period which ended on 31 March 2012 (the “Relevant Period”). The Disputed Sum was paid by SCL to the Republic of Ireland’s National Asset Management Agency (“NAMA”) and SCL claims it is entitled to deduct the amount of the payment in calculating its corporation tax liabilities (whether by reference to the gain realised by SCL or pursuant to the loan relationship rules).
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Published 22 June 2026