InAmalgamated Metal Corporation v HMRC[2017] UKFTT 705 (25 September 2017) the FTT found that a payment of damages made to compensate the recipient for the fact that it had not received a payment of interest from HMRC was itself taxable as interest.
AMC was a company resident in the UK which paid advanced corporation tax (ACT) on dividends paid to its EU parent. It had become aware of the ACT group litigation order (ACT GLO) and instructed its solicitors Wragge & Co to pursue claims on its behalf. Following an offer to settle made by HMRC AMC had instructed Wragge to settle only its in-time claims; but Wragge had agreed...
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InAmalgamated Metal Corporation v HMRC[2017] UKFTT 705 (25 September 2017) the FTT found that a payment of damages made to compensate the recipient for the fact that it had not received a payment of interest from HMRC was itself taxable as interest.
AMC was a company resident in the UK which paid advanced corporation tax (ACT) on dividends paid to its EU parent. It had become aware of the ACT group litigation order (ACT GLO) and instructed its solicitors Wragge & Co to pursue claims on its behalf. Following an offer to settle made by HMRC AMC had instructed Wragge to settle only its in-time claims; but Wragge had agreed...
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