Heather Self (Pinsent Masons) examines the FTT decision where a UK corporate taxpayer succeeded in an argument about loan relationships or financial instruments against HMRC.
The Smith & Nephew case (Smith and Nephew Overseas Ltd; T P Ltd; and Smith and Nephew Finance Holdings Ltd v HMRC [2017] UKFTT 151 reported in Tax Journal 10 March 2017) concerned three Smith & Nephew companies (the appellants) which were dormant subsidiaries with large intercompany balances due to them from their immediate parent company Smith & Nephew Investment Holdings Ltd (SNIH). The existence of these balances meant that a certain amount of accounting and tax compliance work was required in respect of companies which were otherwise dormant so the group wanted to tidy up the position. On 12 November 2008 SNIH wrote to HMRC with what appears to have been a sensible proposal: the balances would be waived ...
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Heather Self (Pinsent Masons) examines the FTT decision where a UK corporate taxpayer succeeded in an argument about loan relationships or financial instruments against HMRC.
The Smith & Nephew case (Smith and Nephew Overseas Ltd; T P Ltd; and Smith and Nephew Finance Holdings Ltd v HMRC [2017] UKFTT 151 reported in Tax Journal 10 March 2017) concerned three Smith & Nephew companies (the appellants) which were dormant subsidiaries with large intercompany balances due to them from their immediate parent company Smith & Nephew Investment Holdings Ltd (SNIH). The existence of these balances meant that a certain amount of accounting and tax compliance work was required in respect of companies which were otherwise dormant so the group wanted to tidy up the position. On 12 November 2008 SNIH wrote to HMRC with what appears to have been a sensible proposal: the balances would be waived ...
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