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Corporation Tax- whether the profit on loan notes is subject to the charge to
corporation tax under the loan relationship rules. Construction of s.
84(2)(a) of and paragraph 12 of Schedule 9 to the Finance Act 1996. Profits
realised on loan notes which the company had agreed to appropriate to
share premium account on the issue of shares for the loan notes were not
amounts required to be transferred to its share premium account within the
meaning of s. 84(2)(a); the profit appropriated to share premium account
was not excluded from the scope of s. 84(2)(a) by paragraph 12 of Schedule
9. Appeal and Cross-appeal dismissed.
Published 1 December 2016