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Corporation Tax As A Liquidation Expense

Amanda Rowland and David Leibowitz look at the important decision of the House of Lords in Re Toshoku Finance UK plc [2002] UK HL6

 
Amanda Rowland and David Leibowitz look at the important decision of the House of Lords in Re Toshoku Finance UK plc [2002] UK HL6
 
Toshoku Finance UK plc (Toshoku) was a subsidiary of a Japanese company that went into liquidation in December 1997. Toshoku went into liquidation on 26 January 1998.
 
Its principal asset was a debt of $156.3 million owned to it by TEE a fellow subsidiary of the Japanese parent. As TEE was insolvent Toshoku agreed to accept $21.5 million in full and final settlement of its debt but nothing was paid in respect of interest that had accrued on the debt after the...

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