Market leading insight for tax experts
View online issue

Clavis Liberty 1 LP v HMRC

Was a trading loss incurred by a partnership involved in a composite transaction?

In Clavis Liberty 1 LP v HMRC [2016] UKFTT 253 (18 April 2016) the FTT found that a partnership which had been involved in a composite transaction with circular money flows had not incurred a trading loss.

The appeal concerned a closure notice denying a trading loss. The dispute related to a £60m dividend received by the partnership from Helios (a company incorporated in the Cayman Islands). However the partnership contended that this was the income of Dickens Ventures (a company incorporated in the British Virgin Islands) by virtue of the sale of the right to receive that dividend by Dickens to Helios without any sale of the shares to which the dividends related (ICTA 1988 s 730). The dispute also related to the deductibility of professional fees paid by the partnership for...

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:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top