Corporation tax – scheme to avoid corporation tax on chargeable gains – whether derivative transactions gave rise to chargeable gains and losses – whether loss arising on disposal of shares in group company was an allowable loss – ICTA, s 128 and TCGA, s 2 and s 143 – application of Ramsay principle – whether interest costs for scheme borrowings had an unallowable purpose – FA 1996, Sch 9, para 13
[2011] UKFTT 414 (TC)
Bailii
England and Wales
Corporation Tax
Updated: 02 November 2021; Ref: scu.443107