References: [2015] UKUT 75 (TCC)
Links: Bailii
UTTC Ratio CORPORATION TAX – company lends money to another group company on terms that shares are paid to a different group company – is the value of the shares income of the lender under the loan relationship rules? – no, but only because of the effect of s. 80(5) of the Finance Act 1996 – is the value of the shares income of the share recipient? – yes – appeals dismissed.
Last Update: 20-Apr-16
Ref: 549071