The Commissioners for HM Revenue and Customs v Investec Asset Finance Plc and Investec Bank Plc:[2018] UKUT 0069 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Arnold and Judge Hellier on 4 April 2018.
Read the full decision in .
Corporation tax – Purchase by traders of partnership interests and adherence to partnerships followed by realisation and distribution by partnerships of receivables – whether purchase price of partnership interests and contributions to capital of partnerships were capital or revenue expenditure – if revenue, whether incurred wholly and exclusively for purposes of traders’ trades – if revenue incurred wholly and exclusively, whether HMRC entitled to raise further issue not in closure notice – whether partnership profits distributed to traders subject to two tax computations.
Published 4 April 2018