Corporation tax – loan relationships – Appellant sued bank for damages for mis-sold interest rate hedging product – litigation settled on basis that pounds 3.5 million of existing debt to the bank was ‘released and discharged’ by way of settlement of the damages claim – whether this amounted to a ‘related transaction’ – yes – whether the pounds 3.5 million potentially represented a ‘profit’ for loan relationship purposes – yes – whether it arose to the Appellant from its loan relationships or related transactions – held no, it arose from the settlement of the underlying damages claim – therefore taxable under general principles rather than loan relationship regime – appeal allowed
Citations:
[2022] UKFTT 137 (TC)
Links:
Jurisdiction:
England and Wales
Corporation Tax
Updated: 05 June 2022; Ref: scu.677941