Bluecrest Capital Management Cayman Ltd and Others v Revenue and Customs (Corporation Tax/Income Tax – Acquisition By Cayman Islands Limited Partnership): FTTTx 17 Jul 2020

CORPORATION TAX/INCOME TAX – Acquisition by Cayman Islands limited partnership (of which Cayman Islands limited company general partner) of 19% interest in UK limited partnership financed through borrowing – Profit allocation of UK limited partnership made to general partner of Cayman Islands limited partnership – Whether all members of Cayman Islands limited partnership members of UK limited partnership – Whether entitled to a deduction for interest on borrowing – If so, should any deduction be reduced under loan relationship provisions – Whether bank loan and loan notes classified as ‘trading loan relationships’ or ‘non-trading loan relationships’ – Whether discovery amendment valid – Appeal dismissed

[2020] UKFTT 298 (TC)
England and Wales

Corporation Tax

Updated: 22 January 2022; Ref: scu.653135