Keighley on the loan relationship rules, Clipperton on purposive construction and the introduction of the Reserved Investor Fund are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
Keighley: control in the connected parties test and unallowable purpose
The decision of the First-tier Tribunal (FTT) in J Keighley and another v HMRC [2024] UKFTT 30 TC included some interesting points on the loan relationship rules. The FTT had to determine (amongst many other issues) whether a corporation tax loss on the write-off of a loan between two companies should be denied either on the basis that the borrower and lender were connected companies or failing that under the unallowable purpose rule.
James Keighley (JK) owned shares in a company (Primeur) and he as well as Barry Minal (BM) another Primeur shareholder owned shares in a second company (VDP). Under the...
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Keighley on the loan relationship rules, Clipperton on purposive construction and the introduction of the Reserved Investor Fund are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
Keighley: control in the connected parties test and unallowable purpose
The decision of the First-tier Tribunal (FTT) in J Keighley and another v HMRC [2024] UKFTT 30 TC included some interesting points on the loan relationship rules. The FTT had to determine (amongst many other issues) whether a corporation tax loss on the write-off of a loan between two companies should be denied either on the basis that the borrower and lender were connected companies or failing that under the unallowable purpose rule.
James Keighley (JK) owned shares in a company (Primeur) and he as well as Barry Minal (BM) another Primeur shareholder owned shares in a second company (VDP). Under the...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
