In DCC Holdings (UK) Ltd v HMRC (Supreme Court – 15 December) a UK company (D) entered into a number of sale and repurchase ‘repo’ transactions with an Irish bank. It purchased gilts for £812 000 000 and resold them for £785 000 000 having received ‘coupon’ payments totalling £28 800 000. Accordingly these transactions produced an economic and accounting profit of £1 800 000. However in its tax return D did not include a credit entry for the £28 800 000 ‘coupon’ which it had received and claimed that it should be treated as having made a loss of £27 000 000. HMRC rejected the claim and issued an amendment to D's return. D appealed contending that its claim complied with ICTA 1988 s 730A and FA 1996 ss 84 97. The Supreme Court unanimously rejected this contention and...
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In DCC Holdings (UK) Ltd v HMRC (Supreme Court – 15 December) a UK company (D) entered into a number of sale and repurchase ‘repo’ transactions with an Irish bank. It purchased gilts for £812 000 000 and resold them for £785 000 000 having received ‘coupon’ payments totalling £28 800 000. Accordingly these transactions produced an economic and accounting profit of £1 800 000. However in its tax return D did not include a credit entry for the £28 800 000 ‘coupon’ which it had received and claimed that it should be treated as having made a loss of £27 000 000. HMRC rejected the claim and issued an amendment to D's return. D appealed contending that its claim complied with ICTA 1988 s 730A and FA 1996 ss 84 97. The Supreme Court unanimously rejected this contention and...
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