Tanja Velling (Slaughter and May) reviews a significant FTT decision in which the taxpayers were denied interest deductions on a loan created in an intra-group reorganisation under the unallowable purpose rule.
In Syngenta Holdings Ltd v HMRC [2024] UKFTT 998 (TC) a new decision on the unallowable purpose rule in CTA 2009 s 441 the First-tier Tribunal denied all interest deductions because the relevant loan had a tax avoidance purpose. It came out shortly after BlackRock [2024] EWCA Civ 330 Kwik-Fit [2024] EWCA Civ 434 and JTI [2024] EWCA Civ 652 reached the end of the road (the Court of Appeal’s decisions are final after the Supreme Court denied permission to appeal). So as one chapter closes another one opens (although it is unclear whether Syngenta will go beyond the FTT).
Syngenta in summary
The Swiss-headed Syngenta Group is a global agriculture business. Before an...
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Tanja Velling (Slaughter and May) reviews a significant FTT decision in which the taxpayers were denied interest deductions on a loan created in an intra-group reorganisation under the unallowable purpose rule.
In Syngenta Holdings Ltd v HMRC [2024] UKFTT 998 (TC) a new decision on the unallowable purpose rule in CTA 2009 s 441 the First-tier Tribunal denied all interest deductions because the relevant loan had a tax avoidance purpose. It came out shortly after BlackRock [2024] EWCA Civ 330 Kwik-Fit [2024] EWCA Civ 434 and JTI [2024] EWCA Civ 652 reached the end of the road (the Court of Appeal’s decisions are final after the Supreme Court denied permission to appeal). So as one chapter closes another one opens (although it is unclear whether Syngenta will go beyond the FTT).
Syngenta in summary
The Swiss-headed Syngenta Group is a global agriculture business. Before an...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
