The Stagecoach case (Stagecoach Group PLC & Anor v HMRC [2016] UKFTT 120) is yet another complex intra-group financing scheme promoted by one of the ‘big four’ – this time KPMG – where the FTT has found in favour of HMRC. As I commented in my article on the Ladbroke case (Tax Journal 15 January 2016) there is something of a theme emerging here.
The case related to a relatively recent accounting period ending on 30 April 2011. Indeed HMRC was quite prompt in issuing closure notices in September 2013 but it took a further two years before the case reached the tribunal and another seven months before the decision was issued.
The Stagecoach group wanted to recapitalise two subsidiaries Holdings and Transport. Instead of doing this in a straightforward way it took detailed tax advice and used a forward subscription agreement (FSA)...
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The Stagecoach case (Stagecoach Group PLC & Anor v HMRC [2016] UKFTT 120) is yet another complex intra-group financing scheme promoted by one of the ‘big four’ – this time KPMG – where the FTT has found in favour of HMRC. As I commented in my article on the Ladbroke case (Tax Journal 15 January 2016) there is something of a theme emerging here.
The case related to a relatively recent accounting period ending on 30 April 2011. Indeed HMRC was quite prompt in issuing closure notices in September 2013 but it took a further two years before the case reached the tribunal and another seven months before the decision was issued.
The Stagecoach group wanted to recapitalise two subsidiaries Holdings and Transport. Instead of doing this in a straightforward way it took detailed tax advice and used a forward subscription agreement (FSA)...
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:
