Financial dealers, partnerships and corporation tax
In Investec Asset Finance Plc and another v HMRC[2020] EWCA Civ 579 (29 April) the Court of Appeal considered a number of issues relating to the tax treatment of an investment structure involving a mixture of partnerships and companies.
The two appellant companies entered into a series of complex transactions under which they became partners in a number of leasing partnerships. They incurred costs in acquiring their interests in the partnerships and subsequently made further capital contributions to them. Shortly afterwards the partnerships sold off their assets receiving large sums of money which generated profits in their hands. Much of the money was then paid over to the appellants.
There were three issues for the court to consider. The first issue was whether the capital contributions were deductible in computing the taxable profits of the solo financial trades carried on...
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Financial dealers, partnerships and corporation tax
In Investec Asset Finance Plc and another v HMRC[2020] EWCA Civ 579 (29 April) the Court of Appeal considered a number of issues relating to the tax treatment of an investment structure involving a mixture of partnerships and companies.
The two appellant companies entered into a series of complex transactions under which they became partners in a number of leasing partnerships. They incurred costs in acquiring their interests in the partnerships and subsequently made further capital contributions to them. Shortly afterwards the partnerships sold off their assets receiving large sums of money which generated profits in their hands. Much of the money was then paid over to the appellants.
There were three issues for the court to consider. The first issue was whether the capital contributions were deductible in computing the taxable profits of the solo financial trades carried on...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
