Travel Document Service and Another v The Commissioners for HM Revenue and Customs: [2017] UKUT 0045 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Arnold and Judge Herrington on 7 February 2017.
Read the full decision in .
Corporation tax – tax avoidance scheme – use of total return swap over shares in subsidiary to create a deemed creditor relationship – value of shares depressed by novating liability for large loans to subsidiary – whether loan relationships had unallowable purpose – whether debits attributable to unallowable purpose.
Published 21 February 2017