SCIT TRANSFERS OF SECURITIES – loan notes provided for a fixed rate of interest of 7.43375% from issue to redemption but also provided for interest to be paid on irregular days and in irregular amounts – whether loan notes carried interest at a rate which was a fixed rate which was the same throughout the period from issue to redemption – no – whether inspector made a just and reasonable determination – yes – appeal dismissed – ICTA 1988 S717(2)(a) and (9)
Citations:
[2004] UKSC SPC00441
Links:
Income Tax
Updated: 28 June 2022; Ref: scu.221410