Alan Dolton Editor of Tolley's Tax Cases and Tolley's VAT Cases gives us the latest tax case news
Prudential plc v HMRC (CA – 25 June)
The CA has unanimously upheld the Ch D decision in favour of HMRC reported at [2008] STC 2820. A company (P) submitted a return claiming a non-trading loan relationship debit of £105 000 000 relating to two payments made at the inception of two 'swap' transactions which had taken place in that period. HMRC began an enquiry into P's return. It formed the opinion that the payments were not 'qualifying payments' within FA 1994 s 151. HMRC therefore issued an amendment to...
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Alan Dolton Editor of Tolley's Tax Cases and Tolley's VAT Cases gives us the latest tax case news
Prudential plc v HMRC (CA – 25 June)
The CA has unanimously upheld the Ch D decision in favour of HMRC reported at [2008] STC 2820. A company (P) submitted a return claiming a non-trading loan relationship debit of £105 000 000 relating to two payments made at the inception of two 'swap' transactions which had taken place in that period. HMRC began an enquiry into P's return. It formed the opinion that the payments were not 'qualifying payments' within FA 1994 s 151. HMRC therefore issued an amendment 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:
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