Cross loans were made between an investment company and pension schemes. The overall effect was to create payments which could be set off against Corporation Tax. They were not a pre-ordained series of transactions where the underlying loans were genuine, and the payments were made in respect of a genuine accrual of interest. Citations: Times … Continue reading McNiven (Inspector of Taxes) v Westmoreland Investments Ltd: CA 26 Oct 1998
Interest payments capitalized for stated period deductible as charge on income. Citations: Ind Summary 18-Dec-1995 Statutes: Income and Corporation Taxes Act 1988 338 Jurisdiction: England and Wales Income Tax Updated: 04 June 2022; Ref: scu.83265
Loans made between associated companies for the sole purpose of creating a charge to tax were ineffective as avoidance scheme. Citations: Times 19-Aug-1997 Statutes: Income and Corporation Taxes Act 1988 338 Jurisdiction: England and Wales Cited by: At ChD – McNiven (Inspector of Taxes) v Westmoreland Investments Ltd CA 26-Oct-1998 Cross loans were made between … Continue reading McNiven (Inspector of Taxes) v Westmoreland Investments Ltd: ChD 19 Aug 1997
A company is not allowed to allocate set offs of interest payments against foreign income in such a way as merely served with double taxation relief to carry forward the maximum amount of loss. Citations: Times 20-Jan-1999 Statutes: Income and Corporation Taxes Act 1988 338(1) 393(9) 797(3) Jurisdiction: England and Wales Income Tax Updated: 10 … Continue reading Commercial Union Assurance Co Plc v Shaw (Inspector of Taxes): CA 20 Jan 1999
Yearly interest payment is treated as having been paid when it is debited to bank account. Citations: Times 13-Nov-1995 Statutes: Income and Corporation Taxes Act 1988 338 Jurisdiction: England and Wales Corporation Tax Updated: 28 April 2022; Ref: scu.83266
The fact that a payment of interest was made only to create a tax advantage did not prevent its being properly claimed. Interest was paid for the purposes of setting it against tax, when the debt was discharged. A company with substantial losses had . .
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