What is and is not a loan relationship? Graham Iversen reviews the recent decision of the Upper Tribunal in MJP Media Services
The Upper Tribunal has recently released its decision in MJP Media Services Ltd v HMRC [2011] UKUT 100 (TCC) a case which is being followed with interest by many tax advisers in the City.
At the heart of the case is an important issue relating to the application of the loan relationships regime although the point is somewhat obscured by the factual uncertainties of the case.
By way of brief summary of the background MJP was an indirect wholly owned subsidiary of Aegis Group plc (Aegis).
Certain transactions took place between MJP and Aegis which...
