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Ladbroke, unallowable purpose and deemed loans

Heather Self (Blick Rothenberg) examines the Court of Appeal judgment in Ladbroke and its wider implications.
 

Who remembers Green Shield Stamps? In the days before loyalty cards small stamps were collected at petrol stations or Tesco stores and completed books were exchanged for goods such as a kettle or toaster.

In 1977 Tesco decided to stop giving trading stamps and to reduce its prices combined with a promotion campaign called ‘operation checkout’. The success of the campaign led to an increase in stock of some £37m and hence to a claim for stock relief (a tax deduction designed to give a measure of relief for the inflationary effects of increases in stock at a time of high inflation). The Inland Revenue (as it then was) sought to reduce the claim on the grounds that there had been ‘a major alteration in the conduct of...

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