The Court of Appeal in JTI decides that the FTT’s finding that there was no commercial purpose cannot be overturned so all the debits are attributable to the unallowable purpose and disallowed. The Court of Appeal in Altrad decides that a disclosed arrangement intended to deliver capital allowances in respect of ‘magical’ expenditure did not survive HMRC’s Ramsay challenge. The Upper Tribunal’s decision in Burlington on the application of the purpose test in the UK/Ireland tax treaty is good news for the secondary debt market.
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The Court of Appeal in JTI decides that the FTT’s finding that there was no commercial purpose cannot be overturned so all the debits are attributable to the unallowable purpose and disallowed. The Court of Appeal in Altrad decides that a disclosed arrangement intended to deliver capital allowances in respect of ‘magical’ expenditure did not survive HMRC’s Ramsay challenge. The Upper Tribunal’s decision in Burlington on the application of the purpose test in the UK/Ireland tax treaty is good news for the secondary debt market.
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
