Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Union Castle: transfer pricing applies to shareholder transactions
There are a number of interesting points in the Upper Tribunal’s (UT) judgment in Union Castle Mail Steamship Company v HMRC [2018] UKUT 316 (TCC). The case considers whether an accounting debit linked to the derecognition of derivative contracts fairly represented a loss arising on derivative contracts for the purposes of corporation tax under FA 2002 Sch 26 now rewritten in CTA 2009. The derecognition of the derivatives was triggered by the issue of bonus shares carrying dividend rights which entitled the shareholder to the economic benefit of 95% of the derivatives. In July 2016 the First-tier Tribunal (FTT) decided the case in favour of HMRC on the basis that there was no loss because Union Castle remained entitled to...
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Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Union Castle: transfer pricing applies to shareholder transactions
There are a number of interesting points in the Upper Tribunal’s (UT) judgment in Union Castle Mail Steamship Company v HMRC [2018] UKUT 316 (TCC). The case considers whether an accounting debit linked to the derecognition of derivative contracts fairly represented a loss arising on derivative contracts for the purposes of corporation tax under FA 2002 Sch 26 now rewritten in CTA 2009. The derecognition of the derivatives was triggered by the issue of bonus shares carrying dividend rights which entitled the shareholder to the economic benefit of 95% of the derivatives. In July 2016 the First-tier Tribunal (FTT) decided the case in favour of HMRC on the basis that there was no loss because Union Castle remained entitled 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:
