INCOME TAX/CORPORATION TAX – Acquisition of Barclays Global Investors – Loan notes issued to parent company to finance investment – Whether loans would have been on the same terms and in the same amounts if between independent enterprises – If not, would independent enterprises have entered into the loans – Whether ‘main purpose’ of loan relationship was to secure a tax advantage – If so, what was the amount of any debit attributable to such a purpose – Appeal allowed
Citations:
[2020] UKFTT 443 (TC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 27 September 2022; Ref: scu.656836