Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Loss streaming after succession of trade
In Leekes Ltd v HMRC [2018] EWCA Civ 1185 the Court of Appeal unanimously agreed with the Upper Tribunal’s construction of ICTA 1988 s 343 that loss streaming is required.
Leekes carries on the trade of running out-of-town department stores. Leekes purchased the entire share capital of Coles for £1 in November 2009. At the time of the acquisition Coles had trading losses in excess of £2m. Coles carried on a similar trade to Leekes from three furniture stores and a distribution centre. Following the acquisition the business of Coles was hived up into Leekes which then carried on the combined trade. The Coles stores were rebranded as Leekes stores but they were not profitable. In 2010 Leekes made a claim to...
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Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Loss streaming after succession of trade
In Leekes Ltd v HMRC [2018] EWCA Civ 1185 the Court of Appeal unanimously agreed with the Upper Tribunal’s construction of ICTA 1988 s 343 that loss streaming is required.
Leekes carries on the trade of running out-of-town department stores. Leekes purchased the entire share capital of Coles for £1 in November 2009. At the time of the acquisition Coles had trading losses in excess of £2m. Coles carried on a similar trade to Leekes from three furniture stores and a distribution centre. Following the acquisition the business of Coles was hived up into Leekes which then carried on the combined trade. The Coles stores were rebranded as Leekes stores but they were not profitable. In 2010 Leekes made a claim to...
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:
