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Standfast Corporate Underwriters Ltd v Revenue and Customs: FTTTx 12 Feb 2014

FTTTx Corporation tax – corporate underwriter at Lloyd’s – application of anti-loss buying restriction in s227A Finance Act 1994 – taxpayer owned by consortium during period of ‘group-relief continuity condition’ in s227A(5), subsequently acquired as wholly-owned subsidiary of one of the consortium members – then seeking to surrender in later period, by way of group … Continue reading Standfast Corporate Underwriters Ltd v Revenue and Customs: FTTTx 12 Feb 2014