Gerald Montagu (Gide Loyrette Nouel) examines the First-tier Tribunal decision in Lloyds Asset Leasing Ltd.
What was Lloyds about?
Lloyds Asset Leasing Ltd v HMRC [2025] UKFTT 57 (TC) concerned claims by some hundred subsidiaries of Lloyds Banking Group to surrenders of CBGR in respect of £3.8bn of losses incurred by Bank of Scotland Ireland Limited (BOSI) as a result of real estate loans that went bad in the aftermath of the 2008 crash. The not insignificant sum of £1 070 323.24 of corporation tax was at stake.
The First-tier Tribunal identified three principal legal questions whether:
(i) the ‘qualifying loss’ condition in CTA 2010 s 119 was met for BOSI’s accounting period that ended on 31 December 2010;
(ii) prior to 17 September 2010 when BOSI was owned by a Dutch intermediary company Scotland International Finance BV (SIF BV) the ‘precedence...
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:
Gerald Montagu (Gide Loyrette Nouel) examines the First-tier Tribunal decision in Lloyds Asset Leasing Ltd.
What was Lloyds about?
Lloyds Asset Leasing Ltd v HMRC [2025] UKFTT 57 (TC) concerned claims by some hundred subsidiaries of Lloyds Banking Group to surrenders of CBGR in respect of £3.8bn of losses incurred by Bank of Scotland Ireland Limited (BOSI) as a result of real estate loans that went bad in the aftermath of the 2008 crash. The not insignificant sum of £1 070 323.24 of corporation tax was at stake.
The First-tier Tribunal identified three principal legal questions whether:
(i) the ‘qualifying loss’ condition in CTA 2010 s 119 was met for BOSI’s accounting period that ended on 31 December 2010;
(ii) prior to 17 September 2010 when BOSI was owned by a Dutch intermediary company Scotland International Finance BV (SIF BV) the ‘precedence...
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:
