Fidex Ltd v HM Revenue and Customs: CA 21 Apr 2016

‘This appeal is concerned with a tax avoidance scheme called Project Zephyr. The object of this scheme was to create a loss of around 84 million Euros in the hands of the appellant (‘Fidex’) which would be available for group relief throughout the BNP Paribas group of companies of which Fidex forms a part.’

Arden, Kitchin, LJJ, Sir Stephen Richards
[2016] EWCA Civ 385, [2016] STC 1920, [2016] BTC 16, [2016] 4 All ER 1063
Finance Act 1996
England and Wales
At FTTXFidex Ltd v Revenue and Customs FTTTx 2-Apr-2013
FTTTx CORPORATION TAX – loan relationships – debit under paragraph 19A, Schedule 9, Finance Act 1996 in respect of the difference in the accounting value of loan relationships on a change of accounting practice – . .
Appeal fromFidex Limited v Revenue and Customs UTTC 13-Nov-2014
Procedure – appeal against closure notice – reliance on grounds for amendment not stated in closure notice – Tower McCashback considered Corporation tax – loan relationships – application of paragraph 13 Sch9 FA 1996 to debit arising under para19A . .

Lists of cited by and citing cases may be incomplete.

Taxes Management, Corporation Tax

Updated: 01 November 2021; Ref: scu.562450