GDF Suez Teesside Ltd v Revenue and Customs: UTTC 17 Feb 2017

UTTC CORPORATION TAX – avoidance scheme – transfer of contingent, unrecognised, claim against third party to subsidiary in exchange for shares – subsidiary recognising value of asset despite contingency but parent not recognising shares – whether accounting GAAP-compliant – yes – loan relationship rules – whether FA 1996 s 84(1) engaged – yes – recognised value of asset to be brought into account as credit in parent’s corporation tax computation -appeal dismissed
PROCEDURE – opening of enquiry – whether error in identification of accounting period invalidates enquiry – no, if intention clear.

Citations:

[2017] UKUT 68 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 04 February 2022; Ref: scu.577814