In Farnborough Airport Properties Company and another v HMRC [2017] UKUT 394 (4 October 2017) the UT found that the appointment of a receiver had the effect of degrouping a company for group relief purposes.
The appellants (referred to collectively as ‘Farnborough’) were each at least 75% subsidiaries of Kelucia (‘KL’) as was Piccadilly Hotels 2 (‘PH2L’). HMRC had disallowed Farnborough’s claims for group relief of £10.5m under CTA 2010 s 154 in relation to losses surrendered by PH2L on the ground that PH2L had ceased to be a member of the same group of companies as Farnborough as a result of the appointment of receivers over PH2L. The issue was...
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In Farnborough Airport Properties Company and another v HMRC [2017] UKUT 394 (4 October 2017) the UT found that the appointment of a receiver had the effect of degrouping a company for group relief purposes.
The appellants (referred to collectively as ‘Farnborough’) were each at least 75% subsidiaries of Kelucia (‘KL’) as was Piccadilly Hotels 2 (‘PH2L’). HMRC had disallowed Farnborough’s claims for group relief of £10.5m under CTA 2010 s 154 in relation to losses surrendered by PH2L on the ground that PH2L had ceased to be a member of the same group of companies as Farnborough as a result of the appointment of receivers over PH2L. The issue was...
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