FTTTx Income tax – claim for relief for interest paid under s 353 ICTA – whether payment of net present value of interest to accrue was ‘interest’ eligible for relief – whether interest paid in excess of a reasonable commercial rate – whether interest relief was sole or main benefit expected to accrue to taxpayer from the transaction under which the interest was paid – s 787 ICTA
Settlement agreement – s 54 TMA, s 5 CRCA – whether ultra vires as a forward tax agreement – whether voidable for material non-disclosure – whether applicable for periods after disposal by taxpayer of relevant investments
[2012] UKFTT 499 (TC)
Bailii
England and Wales
Income Tax, Taxes Management
Updated: 09 November 2021; Ref: scu.466086
