Heather Self (Pinsent Masons) examines the Court of Appeal decision in Greene King PLC and Greene King Acquisitions Ltd v HMRC.
The Court of Appeal decision in Greene King PLC and Greene King Acquisitions Ltd v HMRC [2016] EWCA Civ 782 (reported at page 4) has now been released a mere three weeks after the hearing at the beginning of July. Although HMRC’s press release (www.bit.ly/2apxnsl) says that it has ‘defeated a tax avoidance scheme protecting around £30m in tax’ the decision is significantly more favourable to the taxpayer than the earlier decision in the Upper Tribunal.
The facts
In 2000 Greene King PLC (PLC) lent £300m to a subsidiary Greene King Brewing and Retailing Ltd (GKBR). This was a straightforward loan relationship on which GKBR claimed deductions for interest costs....
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Heather Self (Pinsent Masons) examines the Court of Appeal decision in Greene King PLC and Greene King Acquisitions Ltd v HMRC.
The Court of Appeal decision in Greene King PLC and Greene King Acquisitions Ltd v HMRC [2016] EWCA Civ 782 (reported at page 4) has now been released a mere three weeks after the hearing at the beginning of July. Although HMRC’s press release (www.bit.ly/2apxnsl) says that it has ‘defeated a tax avoidance scheme protecting around £30m in tax’ the decision is significantly more favourable to the taxpayer than the earlier decision in the Upper Tribunal.
The facts
In 2000 Greene King PLC (PLC) lent £300m to a subsidiary Greene King Brewing and Retailing Ltd (GKBR). This was a straightforward loan relationship on which GKBR claimed deductions for interest costs....
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
