FTT denies cross-border group relief claim on main purpose grounds.
In Lloyds Asset Leasing Ltd v HMRC [2025] UKFTT 57 (TC) (20 January) the First-tier Tribunal (FTT) dismissedthe taxpayer’s appeal against HMRC’s disallowance of its cross-border group relief (CBGR) claim.
The appellant Lloyds Asset Leasing Ltd (LAL) was one of 100 subsidiaries of Lloyds Banking Group (LBG) that claimed CBGR in respect of losses incurred by Bank of Scotland Ireland Ltd (BOSI). This appeal concerned whether LAL was entitled to that relief in accordance with the provisions of CTA 2010 Part 5 Chapter 3 (since repealed).
BOSI an Irish regulated banking entity had become a subsidiary of LGB following the acquisition of Halifax Bank of Scotland plc by the Lloyds group during the 2008 financial crisis. The Irish economy had been hit hard and in 2009 the strategic decision was taken that LBG...
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FTT denies cross-border group relief claim on main purpose grounds.
In Lloyds Asset Leasing Ltd v HMRC [2025] UKFTT 57 (TC) (20 January) the First-tier Tribunal (FTT) dismissedthe taxpayer’s appeal against HMRC’s disallowance of its cross-border group relief (CBGR) claim.
The appellant Lloyds Asset Leasing Ltd (LAL) was one of 100 subsidiaries of Lloyds Banking Group (LBG) that claimed CBGR in respect of losses incurred by Bank of Scotland Ireland Ltd (BOSI). This appeal concerned whether LAL was entitled to that relief in accordance with the provisions of CTA 2010 Part 5 Chapter 3 (since repealed).
BOSI an Irish regulated banking entity had become a subsidiary of LGB following the acquisition of Halifax Bank of Scotland plc by the Lloyds group during the 2008 financial crisis. The Irish economy had been hit hard and in 2009 the strategic decision was taken that LBG...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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